ML22004A367
| ML22004A367 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/02/2022 |
| From: | Mortensen H Physicians for Social Responsibility Wisconsin |
| To: | Office of Administration |
| References | |
| 86FR62220 00037, NRC-2020-0277 | |
| Download: ML22004A367 (148) | |
Text
1/4/22, 3:40 PM blob:https://www.fdms.gov/7da4a2ac-5b85-4b42-b475-b4a3d8f42163 blob:https://www.fdms.gov/7da4a2ac-5b85-4b42-b475-b4a3d8f42163 1/1 PUBLIC SUBMISSION As of: 1/4/22 3:39 PM Received: January 02, 2022 Status: Pending_Post Tracking No. kxy-2kbt-9sha Comments Due: January 03, 2022 Submission Type: Web Docket: NRC-2020-0277 Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Unit Nos. 1 and 2 Comment On: NRC-2020-0277-0194 NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Units 1 and 2 Document: NRC-2020-0277-DRAFT-0233 Comment on FR Doc # 2021-24407 Submitter Information Name: Hannag Mortensen Address:
WI, Email:info@psrwisconsin.org General Comment See attached file(s):
"Comments for PBNP draft EIS.docx"
Attachments DeclarationGundersen DeclarationCompaan DeclarationCooper Comments for PBNP draft EIS SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Phyllis Clark, Stacey Imboden, Mary Neely Comment (37)
Publication Date:
11/9/2021 Citation: 86 FR 62220
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of NextEra Energy Point Beach, LLC (Point Beach Nuclear Plant, Units 1 and 2)
DECLARATION OF ARNOLD GUNDERSEN Under penalty of perjury, I, Arnold Gundersen, declare as follows:
- 1. My name is Arnold Gundersen. I am sui juris. I am over the age of 18-years-old.
- 2. Physicians for Social Responsibility Wisconsin (PSR-WI) has retained Fairewinds Associates, Inc to review a license application to the nuclear regulatory commission to extend the licensed life of NextEras Point Beach nuclear reactors until they have operated for 80-years and a related Environmental Report for NextEra Energy Point Beach, LLCs Point Beach Nuclear Plant, Units 1 and 2. My observations and conclusions are offered to a reasonable degree of scientific certainty based on my experience and relevant information sources.
- 3. This declaration examines and analyzes the technical and environmental issues regarding the License Renewal Request by NextEra for 20-more-years of operation extending the operating life of Point Beach Units 1 and 2 from a 60-year license to an 80-year license.
- 4. I have more than 50 years of experience in Nuclear Engineering, beginning in 1971 when I earned my Bachelor Degree in Nuclear Engineering (BSNE) from Rensselaer Polytechnic Institute (RPI) cum laude. I earned my Master Degree in Nuclear Engineering (MENE) from RPI via an Atomic Energy Commission Fellowship.
December 6, 2020 6, 2013 Docket Nos. 50-266 and 50-301 NRC-2021-0021 March 23, 2021 December 7, 2020
Page 2 of 27 Cooling tower operation and cooling tower plume theory were my areas of study for my Nuclear Engineering Master Degree.
4.1. I began my career as a reactor operator and instructor in 1971 and progressed to the position of Senior Vice President for a nuclear licensee prior to becoming a nuclear engineering consultant and expert witness. My Curriculum Vitae is.
4.2. I have testified as an expert witness to the Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) and Advisory Committee on Reactor Safeguards (ACRS), in Federal Court, the State of Vermont Public Service Board, the State of Vermont Environmental Court, the Florida Public Service Commission, and the California Public Utility Commission (CPUC).
4.3. I am an author of the first edition of the Department of Energy (DOE)
Decommissioning Handbook.
4.4. I have more than 50-years of professional nuclear experience, including and not limited to: Cooling Tower Operation, Cooling Tower Plumes, Consumptive Water Loss, Nuclear Plant Operation, Nuclear Management, Nuclear Safety Assessments, Reliability Engineering, In-service Inspection, Criticality Analysis, Licensing, Engineering Management, Thermohydraulics, Radioactive Waste Processes, Decommissioning, Waste Disposal, Structural Engineering Assessments, Nuclear Fuel Rack Design and Manufacturing, Nuclear Equipment Design and Manufacturing, Prudency Defense, Employee Awareness Programs, Public Relations, Contract Administration, Technical Patents, Archival Storage and Document Control, Source Term Reconstruction, Dose Assessment, Whistleblower Protection, and NRC Regulations and Enforcement.
4.5. I am the chief engineer for Fairewinds Associates, Inc, an expert witness and paralegal services firm specializing in nuclear engineering, nuclear operations, and nuclear power plant safety analysis and assessment.
Page 3 of 27
- 5. Declaration Executive Summary:
5.1. NextEras Point Beach Units 1 and 2 were designed and built more than a half a century ago and are an obsolete and unsafe atomic reactor design. If a corporation applied today to build and operate these reactors, their design would not be approved, as the engineering configuration is unacceptable by todays standards. The reactors do not meet basic licensing requirements that protect the safety of nearby communities. Moreover, the Point Beach reactors' continued operation in their aged and unstable condition put nearby neighborhoods and the people who live and work in those communities at an increased risk for significant radiation exposure due to old, outdated, and poorly maintained equipment. Point Beach (PB) also uses water taken from Lake Michigan to cool its reactors. However, when the reactors finish using Lake Michigan water for cooling, each atomic reactor returns the heated wastewater to the Lake killing hundreds of millions of aquatic organisms yearly. Such actions show these reactors are environmental superpredator.
5.2. Additionally, electricity generated by NextEras Point Beach reactors is more expensive than any form of electricity generated by renewable and sustainable sources, like wind and solar. Closing Point Beach and replacing that electric generating equipment with wind farms or other renewables enables much cheaper sustainable power generators to use the existing Point Beach transmission lines to send much more affordable renewable electricity into Wisconsins Electric Grid. Closing NextEras Point Beach Units 1 and 2 and replacing those vulnerable outmoded atomic reactors with renewables will significantly decrease the cost of electricity in Wisconsin and increase overall employment in Wisconsin. In contrast to continued operation of two aging atomic power plants, replacing that power with renewables would increase income to farmers, and such an arrangement would also maintain Wisconsins tax revenues.
Page 4 of 27
- 6. The Point Beach Reactors Are Obsolete:
6.1. I am 72 years old. In 1964, when I was in 9th grade, the initial engineering began on the two Point Beach design nuclear power reactors. Late in 1970, Point Beach Unit 1 began generating electricity, and three years later, in 1973, Point Beach Unit 2 also began generating electricity. During those years between 1970 and 1973, I earned my Bachelor of Science (BS) in Nuclear Engineering (BSNE), my Master of Engineering (ME) in Nuclear Engineering (MENE), and my AEC Atomic Energy Commission Reactor Operators License. Using a slide rule for calculations, as that was the equipment we all had, I began work at another early nuclear reactor that is now permanently scrapped because it was no longer considered safe.
6.2. When Point Beach was being designed and constructed during the mid to late 1960s, most engineering calculations used slide rules. The analyses that launched John Glenn into orbit and sent men to the moon, as detailed in the movie Hidden Figures, also were conducted using slide rules.1 Mandatory seatbelt laws for automobiles were not promulgated until 1968, and at that time, there were also no pollution controls required on auto engine exhaust. Rivers were so polluted that they caught fire2. As a result of increased air and water pollution, a nascent environmental movement began while Point Beach was under construction.
Congress created the Environmental Protection Agency during the very early 1970s due to the grave ecological challenges throughout the entire U.S. The EPA began its environmental reviews after Point Beach Unit 1 was operating.
6.3. During the mid to late 1960s, when Point Beach was designed and constructed, no large nuclear plants were in operation - large is defined as an electric power output greater than 400 megawatts-electric (MWe). Therefore, there was no template of a successful, safe nuclear power plant to use as a guide.
1 https://www.imdb.com/title/tt4846340/
Page 5 of 27 6.4. Regulatory guidance and oversight were sadly lacking during the construction of Point Beach. The Atomic Energy Commission (AEC), the predecessor to the Nuclear Regulatory Commission (NRC), issued 10CFR50 Appendix A, the first set of General Design Criteria for atomic power plant construction during the early 1970s after construction on Point Beach Unit 1 was already almost complete. More importantly, the AEC implemented 10CFR50 Appendix B as law to ensure Quality Assurance requirements for the construction of all nuclear power plants well after PB Unit 1 started operation.
6.5. Due to its weak oversight of new atomic plant design as PB was being designed and constructed and began operation, Congress replaced the AEC with the NRC in 1975. According to the current website of the Nuclear Regulatory Commission:
Before the NRC was created, nuclear regulation was the responsibility of the AEC, which Congress first established in the Atomic Energy Act of 1946. Eight years later, Congress replaced that law with the Atomic Energy Act of 1954, which for the first time made the development of commercial nuclear power possible. The act assigned the AEC the functions of both encouraging the use of nuclear power and regulating its safety. The AEC's regulatory programs sought to ensure public health and safety from the hazards of nuclear power without imposing excessive requirements that would inhibit the growth of the industry.
This was a difficult goal to achieve, especially in a new industry, and within a short time the AEC's programs stirred considerable controversy.
An increasing number of critics during the 1960s charged that the AEC's regulations were insufficiently rigorous in several important areas, including radiation protection standards, reactor safety, plant siting, and environmental protection By 1974, the AEC's regulatory programs had come under such strong attack that Congress decided to abolish the agency. Supporters and critics of nuclear power agreed that the promotional and regulatory duties of the AEC should be assigned to different agencies. The Energy Reorganization Act of 1974 created the Nuclear Regulatory Commission; it began operations on January 19, 1975.3 [Emphasis Added]
3 https://www.nrc.gov/about-nrc/history.html
Page 6 of 27 6.6. Despite all the unknown elements of the untested PB design, the AEC granted Point Beach a license to operate for its original 40 year design life.
6.7. Therefore, I conclude that Point Beach was designed and constructed during a period of insufficient regulatory oversight. At that time, the Atomic Energy Commission (AEC) was fulfilling its charter to actively promote new, untested atomic reactor designs, like that of Point Beach, without the benefit of adequate safety and environmental guidance.
6.8. Many US atomic reactors have closed or are planning to close shortly due to the inability to operate profitably without the high risk of a meltdown and a considerable investment to adhere to more stringent safety requirements. To date, there are 94 atomic reactors currently operating in the US with an average age of 39 years4.
6.9. The oldest US atomic reactor in operation is Nine Mile Point Unit 1, a Fukushima type reactor design located in upstate New York that went online one year before PB Unit 1 in December 1970.5 6.10. At 50 years old, PB is ten years older than the average US nuclear plant and one of the oldest atomic power sites in the United States.
6.11. In 2004, PB applied for a 20-year extension to its initial 40-year license approved by the NRC. Even then, it was clear that there is absolutely no factual basis to indicate that energy corporations can safely operate nuclear power plants as they approach 60-years of operation. Today, the data clearly shows that no nuclear plant anywhere in the United States has performed beyond 51-years.
6.12. Now, PB chooses to apply for an additional license extension to operate until it is 80-years-old. There is no scientific basis to assure that a 50-year-old atomic 4 https://www.eia.gov/tools/faqs/faq.php?id=228&t=21 5 https://www.eia.gov/tools/faqs/faq.php?id=228&t=21
Page 7 of 27 facility like PB that was originally designed to operate for only 40-years can remain safe to run for 80-years.
- 7. PB is Unsafe 7.1. No nuclear plant in the US could be licensed today to operate with the outmoded safety systems included in PBs design. The NRC has already determined that the design of Point Beach is not safe for newer reactors.
7.2. There are numerous flaws at the Point Beach reactors that make it unsafe for this agency to approve the NextEra license extension to operate Point Beach for 80 years. Therefore, the license extension should be denied.
7.3. The First Problem Is Its Tangential Turbine Hall 7.3.1. Historically, Point Beach and many other early reactors have a turbine hall that is tangential to the reactor building and control room.
7.3.2. In this Point Beach photo (below), you will see the tall rectangular reactor buildings and the shorter, more extended rectangular turbine halls tangential to the reactor and nearer to the lake.6 6 https://madison.com/wsj/news/local/environment/point-beach-owner-seeks-to-run-wisconsins-last-nuclear-plant-for-80-years/article_d50ba0b6-f3ca-5129-81c2-757405a7bec8.html
Page 8 of 27 7.3.3. This tangential design was inexpensive and was later determined to be unsafe. This approach is no longer an acceptable design anywhere in the world.
7.3.4. The PB design is unsafe because a turbine failure will send 600 lb. pieces of shrapnel hurtling at 600 mph into the containment, safety-related components, and the control room.
7.3.5. Construction of reactors built after Point Beach changed the turbine hall's orientation to be radially outward from the containment to protect the control room and its operators, the safety-related components, and the containment from the threat of turbine shrapnel.
7.3.6. The picture below is of the Callaway nuclear facility in Missouri, which incorporates this vital safety improvement.7 7.3.7. By reorienting the direction of the turbine hall to the radially outward design, the shrapnel would fly into the parking lot rather than the safety-related equipment, control room, and containment building in the event of a turbine failure.
7 https://www.themaneater.com/stories/outlook/proposed-bill-would-fund-callaway-nuclear-plant
Page 9 of 27 7.3.8. Turbine failures are likely events. Fermi 2 in Michigan experienced turbine failure, as have other nuclear plants and airplane jet engines.
7.3.9. I have reviewed publicly available photos of the PB turbine hall and see no indication that shielding from turbine missile shields has been implemented. While PB cannot rotate its entire turbine hall to assure that a turbine failure does not result in safety-related consequences, there is a solution. To mitigate the impact of a turbine failure, PB could install an inexpensive Energy Absorbing Turbine Missile Shield, US Patent
- 4397608A8. I conclude that to reduce the risk of damage to safety-related systems, structures, and components, PB should be required to install an energy-absorbing turbine missile shield around its turbine.
7.4. What Is Embrittlement?
7.4.1. Even before Point Beach's design, scientists had discovered that neutron radiation from inside the nuclear core would gradually destroy the thick metal nuclear reactor that surrounds that core. This phenomenon is called neutron embrittlement. If embrittlement becomes extensive, the dense metallic nuclear reactor can shatter like glass. The NRC has identified that NextEras Point Beach Reactors are the most embrittled operating reactors in the United States.
7.4.2. For a video further explaining these phenomena, see:
https://www.fairewinds.org/nuclear-energy-education/nuclear-crack 7.4.3. Reactor embrittlement can cause an atomic reactor to shatter like glass, creating what the Nuclear Regulatory Commission (NRC) calls a Class 9 Accident, which is the worst nuclear catastrophe presently acknowledged by the NRC. When the nuclear core leaves the atomic reactor and melts down into the containment, as it did at three of the atomic reactors at the 8 https://patents.google.com/patent/US4397608A/en
Page 10 of 27 Fukushima Daiichi site in Japan beginning on March 11, 2011, the NRC calls each one of these nuclear calamities a Class 9 Accident.
7.4.4. According to the Nuclear Regulatory Commission, Reactor pressure vessels, which contain the nuclear fuel in nuclear power plants, are made of thick steel plates that are welded together. Neutrons from the fuel in the reactor irradiate the vessel as the reactor is operated.
This can embrittle the steel, or make it less tough, and less capable of withstanding flaws which may be present. Embrittlement usually occurs at a vessel's "beltline," that section of the vessel wall closest to the reactor fuel. Pressurized water reactors (PWRs) are more susceptible to embrittlement than are boiling water reactors (BWRs)....Steels with a higher proportion of copper and nickel will tend to be more susceptible to embrittlement, than are steels with lower proportions of these two elements... 9 7.4.5. Nuclear energy corporations cannot prevent neutron embrittlement of metal; it is similar to a spreading cancer in that engineers can monitor embrittlement progress. To create a viable monitoring program, engineers had numerous samples of the exact metal inside each reactor placed inside the reactor prior to operation. These samples are called coupons, and several are withdrawn periodically and measured in a laboratory to determine the progress of embrittlement.
7.4.6. Engineers designed the Point Beach reactors to operate for 40 years, and the reactors contained enough sample coupons to last for 40 years of operation. Now that the PB reactors are licensed to operate for 60-years, there are not enough coupons in the reactor core to test for embrittlement, let alone for an additional 20 years for the license extension request for 80 years to operate Point Beach.
7.4.7. Ten years after Point Beach became operational in 1981, personnel in the Office of the Governor of California were aware that nuclear reactor 9 NRC Fact Sheet on Reactor Pressure Vessel Issues, Embrittlement, http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/prv.html
Page 11 of 27 embrittlement with its associated risk of a nuclear reactor failure and radiation leak was a serious problem.
7.4.7.1.
Peter H. Gleick, a specialist in the office of Gov. Edmund G.
Browns assistant for energy and environment, wrote a Letter to the Editor of the New York Times dated November 7, 1981.
7.4.7.2.
In that letter, Mr. Gleick said that nuclear reactor embrittlement
...may be the most serious known problem facing existing nuclear power plants... which could cause failure of the pressure vessel containing nuclear fuel. Mr. Gleicks full letter is inserted below.
To the Editor:
If The Pressure Vessel Of A Reactor Cracks Your Oct. 24 editorial Brittle Metal and Nuclear Safety
correctly calls attention to what may be the most serious known problem facing existing nuclear power plants -
pressurized thermal shock, which could cause the failure of the pressure vessel containing the nuclear fuel.
Although progressive embrittlement of the pressure vessel has always been anticipated, it now appears that many such vessels will become susceptible to cracking long before reaching their 30- to 40-year lifespan. This problem, however, is neither as avoidable nor as correctable as you suggest.
As you stated, both overcooling and high pressurization must exist before a vessel can crack. Yet there are situations where rapid cooling together with high pressurization is required in order to avoid a serious accident. The operator actions needed to avoid a serious reactor accident may be completely contradictory to those required to avoid cracking the pressure vessels.
For this reason, the Nuclear Regulatory Commission has taken the position that relying on operator action is not an acceptable solution to the risk of pressure vessel failure.
Similarly, the statement that correcting this problem involves catching the flaw early is accurate but misleading.
Pressurized thermal shock is a problem that is most severe in the older generation of reactors - those built before the
Page 12 of 27 mid-1970's (newer pressure vessels have better materials characteristics and are less susceptible to embrittlement).
As a consequence, catching the flaw early is not possible for most of these older reactors, which are already close to reaching unacceptable levels of embrittlement. Moreover, the solution described in the editorial, annealing of the vessel, requires emptying the entire core of nuclear fuel and heating the highly radioactive pressure vessel to several hundred degrees above its normal operating temperature for a very long period - perhaps up to several months.
Theoretically, the strength of the vessel is then recovered.
In practice, however, no commercial nuclear reactor vessel has ever been annealed, and there are serious questions about the time required, the economic costs, the radiation exposure to workers and, in fact, whether or not this process will be successful.10 7.4.8. Mr. Gleicks 1981 letter to the New York Times was prescient except that he researched and wrote it 10-years after Point Beach Unit 1 began operation.
7.4.9. From the documents I reviewed, it is evident that nuclear industry experts and the Nuclear Regulatory Commission (NRC) have known the seriousness of reactor embrittlement and the radiation release consequences for the public should that failure occur.
7.4.10. In 1982, Demetrios L. Basdekas, an NRC Reactor Safety Engineer, expressed his concerns and frustrations in his letter to the editor, also published in the New York Times:
There is a high, increasing likelihood that someday soon, during a seemingly minor malfunction at any of a dozen or more nuclear plants around the United States, the steel vessel that houses the radioactive core is going to crack like a piece of glass. The result will be a core 10 New York Times, November 7, 1981 New York Times, November 7, 1981 http://www.nytimes.com/1981/11/07/opinion/l-if-the-pressure-vessel-of-a-reactor-cracks-084005.html
Page 13 of 27 meltdown, the most serious kind of accident, which will injure many people, and probably destroy the nuclear industry with it.11 7.5. How Does Embrittlement Lead To The Failure Of The Atomic Reactor?
7.5.1. If the nuclear reactor were to suddenly shut down during one of the dozens of atomic power mishaps that nuclear reactor design engineers and the NRC anticipate will happen, the safety system would immediately inject cool water into the reactor vessel in an attempt to cool the reactor core in hopes of preventing a meltdown.
7.5.2. However, in a seriously embrittled reactor like Point Beach, when that cool water is injected and comes in direct contact with the hot reactor vessel, it can cause Pressurized Thermal Shock (PTS). After this, the 8-inch thick steel reactor vessel may crack from PTS, causing it to break open and release massive radioactivity into the surrounding area and the environment. The sudden breach of the nuclear power reactor would dramatically increase the pressure inside the containment causing this last radiation barrier to fail also.
Should this event occur, the Nuclear Regulatory Commission (NRC) has estimated that it will cause at least 7,000 cancer deaths and $112 Billion in todays dollars in property damage.12 7.5.3. While no atomic reactor mishap, or accident as the industry names them, should be called routine, this rapid cooling and sudden pressurization sequence can cause a radioactive disaster, yet the NRC and nuclear power industry have named them a routine accident.
11 New York Times, March 29, 1982 12 Projected Impacts of Large-scale Radiological Releases at Atomic Reactors in the U.S.
Calculation of Reactor Accident Consequences (CRAC-2) report by U.S. NRC & Sandia National Lab, 1982
Page 14 of 27 7.5.4. There have been several historical precursor sequences that prove that abrupt temperature and pressure changes do occur at operating nuclear power plants.
7.5.4.1.
The first such precursor event happened at Californias Rancho Seco atomic power reactor on March 20, 1978. When a worker dropped a light bulb, it, in turn, caused a cascade of electrical faults.
7.5.4.1.1. Instruments in the control room went haywire, leaving the reactor operators with no accurate instrumentation to rely upon while attempting to control the reactor.
7.5.4.1.2. The temperature inside the reactor dropped from 582ºF to 285ºF in one hour. The reactor pressure dropped from 2,200 psi to 1,600 psi. The reactor pressure jumped back to over 2,000 psi but at a low temperature when the reactor operators injected cold water.
7.5.4.2. The Rancho Seco transient, as industry nuclear engineers call it, was a near miss that made it clear that reactors like Point Beach are susceptible to abrupt changes in temperature and pressure. Fortunately, while the abrupt changes in temperature and pressure severely stressed the nuclear reactor vessel welds, the Pressurized Thermal Shock (PTS) and nuclear vessel failure were avoided at Rancho Seco. Why? A major catastrophe was avoided at Rancho Seco because the reactor was new, and unlike Point Beach, the welds at Rancho Seco were not yet embrittled by long-term neutron bombardment that would have caused the reactor to shatter like glass.
7.5.5. More recent analyses show that an atomic reactor vessel can crack even when it is not under pressure. Hence, the damage the nuclear power industry has named pressurized thermal shock is now as clearly understood as damage from thermal shock. Clipped below is testimony to the NRCs Advisory Committee on Reactor Safeguards in 2014.
Page 15 of 27 Mr. Kirk: well, they're - and that's one of the - in fact, that was very much a surprise because in the - in the early analysis - in the 1980s analysis the no-pressure events were a priori screened out. But what we found in running the calculation is you can run a crack pretty much all the way through the wall.
Member Skillman: just with temperature.
Mr. Kirk: just with temperature.
Member Skillman: just with temperature.
Mr. Kirk: yes. 13 7.5.6. The NRC identified Point Beach as the most embrittled reactor still operating in the US14.
7.5.7. The six most embrittled nuclear reactors in the United States are:
7.5.7.1.
Yankee Rowe (permanently closed 1992) 7.5.7.2.
Genkai-1 (Japan, permanently closed 2015 after discovering coupon samples indicated much higher embrittlement that analysis predicted) 7.5.7.3.
Point Beach 7.5.7.4.
Palisades (closing in 2022) 7.5.7.5.
Indian Point 3 (closing in 2021) 7.5.7.6.
Diablo Canyon 1 (closing in 2024) 7.5.7.7.
Beaver Valley (Scheduled to close in 2021 unless Pennsylvania approves more than a hundred million dollar yearly subsidy.)
7.5.8. Therefore, five of the six most embrittled reactors in the US have already been shuttered or will be closed during the next three years rather than addressing the safety-related embrittlement issue. Only the Point Beach reactors are not scheduled to be closed.
7.6. Is There A Solution To Nuclear Reactor Embrittlement?
7.6.1. It is disturbing to note that the NRC and NextEra's alleged solution to protect Point Beach against cracking and radiation releases from its 13 Advisory Committee on Reactor Safeguards, top of p.33, Oct. 16, 2014 transcript 14 NRC ADAMS Accession No. ML13077A156
Page 16 of 27 increasing neutron embrittlement is simply to develop new operator administrative controls. These administrative controls are requirements that the atomic reactor operators at Point Beach must implement during a reactor emergency to avoid cracking the 8 thick steel atomic power reactor vessel.
7.6.1.1. These administrative controls require the reactor operators to raise the reactor's temperature before increasing the pressure, and unless the operators implement these controls perfectly, the reactor vessel will experience cracking.
7.6.1.2. This situation is analogous to a tractor-trailer driver being informed by his boss that the brakes on the tractor-trailer will fail at speeds above 50 miles per hour. However, rather than fix the brakes, the trucking companys administrative solution is to insist that the truck driver never exceed 49 miles per hour. Just as reactor vessel embrittlement gets significantly worse over time, bad brakes on the truck would demand that the driver reduce his speed further every year, or the truck would be pulled off the road and sold for scrap.
7.7. How Is Reactor Embrittlement Determined?
7.7.1. To measure embrittlement, when the Point Beach reactor vessels were manufactured, identical metallic samples, called coupons, were manufactured as well and were installed in the Point Beach reactors when the reactors were placed on site. The same system is used at other reactors to monitor embrittlement progression.
7.7.2. Originally, Point Beach was designed and anticipated to operate for only 40 years, so only 40-years-worth of coupon samples were manufactured and installed in the reactors. Now there are not enough sample coupons to remove from the reactor and test for embrittlement until the 60-year-license expires, let alone for an additional 20 more years for an 80-year-license to operate.
Page 17 of 27 7.7.3.
Unnervingly and without any scientific proof to do so, the Nuclear Regulatory Commission (NRC) has repeatedly modified its calculations allowing aging, embrittled nukes to continue to operate well past their lifespan and certainly in risky uncharted territory.
7.7.4.
The process of determining the Nil-ductility transition temperature (the temperature below which the vessel will shatter) is not an exact science. A paper written, by Nikolaeva et al., in 2000 supports my assessment of uncertainty and complexity in the development of the embrittlement calculations:
The radiation embrittlement of reactor vessel materials is a complex process, which depends upon the conditions of a radiation in the microstructure and chemical composition of the steel. It is universally acknowledged that phosphorus, copper, nickel intensify the radiation embrittlement of vessel material the most... The presence of a synergistic interaction of elements in the irradiation process and the complex interaction of metallurgical factors and the radiation conditions make it difficult to determine the degree to which impurities and alloying elements influence radiation embrittlement. 15
[Emphasis Added]
7.7.5. The NRC and the Point Beach reactors rely on using engineering analysis to extend the useful life of embrittled nuclear reactors, which has the net effect of reducing the safety margin of Point Beach. A paper written in 2000 by the Nuclear Energy Agency Nuclear Science Committee states that safety margins will be reduced by extending the useful life of embrittled reactors.
As many commercial light water reactors begin to approach the end of their licensed lifetime, nuclear utilities have started to investigate the possibility of extending the operating life of reactors beyond the originally licensed 30-40 years. Longer reactor operating times mean higher neutron and gamma fluence levels and/or smaller safety margins... High energy 15 Embrittlement of Low-Alloy Structural Steel by Neutron Irradiation, Atomic Energy, Vol. 88, No.4, 2000: Nikolaeva, Nikolaev, Kevorkyan, Kryukov & Korolev, http://link.springer.com/article/10.1007%2FBF02673611#page-2
Page 18 of 27 neutron bombardment degrades the structural integrity of RPVs16. [Emphasis Added]
7.7.6. Robert Pollard, a senior nuclear engineer with the Union of Concerned Scientists, was one of the world's first scientists to identify the danger and degree of uncertainty in embrittlement calculations within the nuclear engineering and scientific community.
If you really want a good fight, ask people about the reliability of those safety estimates. The method the NRC and the industry uses is called probabilistic risk assessment. Its designed to get around a rather impressive lack of concrete evidence... In a probabilistic risk assessment, you estimate the likelihood of an event that initiates a transient, then estimate the likelihood of the reaction to that event, the reaction to that reaction, and so on down the line. Westinghouse, for example, has a model that starts with 17 possible initiators and runs through event trees to more than 8,200 end points... But there are inevitable differences of opinion about the value of those calculations... Not everyone agrees with the calculations. The NRC may consult its Ouija board and come up with a number, says Robert Pollard of the Union of Concerned Scientists, but the error bands are so large that it is essentially useless.... Theres no dispute that current emergency systems would not be able to cope with the fracture of the reactor vessel... The defense in depth argument disappears when you talk about pressurized thermal shock.
[Emphasis Added]17 7.8. Even though neutron embrittlement of the Point Beach reactors present a clear and present danger, the NRC and Point Beach have relied upon error-prone analytical calculations rather than use all the tools available to identify just how serious the embrittlement threat has become as Point Beach ages.
16 Prediction Of Neutron Embrittlement In The Reactor Pressure Vessel, Nuclear Energy Agency Nuclear Science Committee, 2000 https://www.oecd-nea.org/science/docs/2000/nsc-doc2000-5.pdf 17 Thermal shock-new nuclear-reactor safety hazard? Edward Edelson, Popular Science, June 1983, http://static1.1.sqspcdn.com/static/f/356082/25715973/1417195845950/June+1983+Popu lar+Science.pdf?token=a42WKwrX5fEjMEeVND6FGLOKmWc%3D
Page 19 of 27 7.8.1. A review of the publicly available files in the NRCs ADAMS database indicates that the NRC has granted waivers for each of the five most embrittled reactors still operating to avoid testing their actual embrittlement through the measurement of their actual metallurgical coupons. At Diablo Canyon, the NRC has allowed the unit to avoid testing any coupon samples for almost two decades, and at Palisades, Indian Point, and Point Beach, I could find no record of coupon samples being tested for at least ten years.
When Yankee Rowe was completely dismantled in 1992, it is unfortunate for the safety of the whole industry that the vessel was not tested to determine how significant its embrittlement was. With so many embrittled atomic reactors closing during the next several years (Indian Point Unit 3 in April 2021, Palisades in 2022, and Diablo Canyon 1 in 2024), we are provided with significant and vital opportunities to perform nuclear autopsies (comprehensive analyses) on those badly embrittled Reactor Pressure Vessels (RPVs) to learn lessons and provide real world physical data for an accurate analysis of the PB 80-year license extension application process.
7.8.2. As the US nuclear fleet ages, the NRC has systematically removed conservative calculational aspects of the embrittlement process to allow continued operation. The NRC has not incorporated the actual data from coupons in the remaining five worst atomic power reactors in the U.S. to be used for the embrittlement analysis applied to NextEras Point Beach reactors to allow their continued operation. Instead of evaluating Point Beachs specific metallurgy, the NRC has allowed Point Beach and its cohorts to use analytical techniques that ignore the data from sample coupons it could readily test. Additionally, there is no scientific basis by which the Point Beach reactors should continue operating unless there is a complete physical analysis of the coupons from its reactors and the five other reactors that are its embrittled cohorts.
Page 20 of 27 7.8.3. Therefore I conclude that Point Beachs continued operation violates 10CFR50 Appendix A, Criterion 14.
Criterion 14Reactor coolant pressure boundary. The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.
7.8.4. During the last 50 years of operation, Point Beach has failed to develop an adequate coupon program to physically test the integrity of the RPV for PB's operational life. As defined in Appendix A Criterion 14, testing obviously does not include analytical techniques prone to error. There is inadequate coupon data specific to PB to justify its continued operation beyond its 50th year, let alone until it reaches 80. BP has been violating GDC 14 by not testing coupons and relying on analytical handwaving instead!
7.8.5. The NRC already knows the Point Beach reactor vessel to be the most embrittled vessel in the nation. PB was not "designed and fabricated to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture. Thus the NRCs acknowledgment proves that the Point Beach reactors fail to meet Criterion
- 14.
- 8. Waivers 8.1. With Point Beachs first license renewal application to change from 40 to 60 years and its most recent license renewal application to operate from 60 to 80 more years, NextEra Corporation has not made any commitments to improve the reactors' physical condition to meet modern safety standards. Instead, NextEra is proposing to create a checklist at the Point Beach reactors that allows for periodically monitoring the degrading state of concrete, pipes, wires, and other systems designed to prevent radiation releases in a disaster that may occur at PB.
8.2. This is an important distinction. Point Beach was designed in 1965 with a design life of 40-years. In its latest application to operate for 80-years, PB is not
Page 21 of 27 committing to meet any new safety criteria. Instead, PB agrees to monitor its mid-1960s design to identify any further degradation in a facility designed before the Nuclear General Design Criteria were implemented and before Nuclear Quality Assurance standards even existed.
8.3. Since there are no nuclear reactors older than 51 years old, PB's proposed monitoring and inspection program is an academic exercise that is not based upon physical or scientific data.
8.4. It is essential to ask what happens when an aging nuclear facility like PB uses this license extension inspection process and identifies material degradation exceeding its license extension commitments? When this occurs, the reactor owner asks for a waiver from the NRC to continue to operate even though it has failed to meet its extended license requirements.
8.5. As current reactors age beyond their original 40-year design life and the NRC approves 40-60 year license extensions, the waiver process allows these degrading and unsafe reactors to continue running even after inspections have identified degradation beyond anticipated levels. The NRC has never closed a nuclear facility when the initial extended inspection plan indicates an exceeded inspection parameter.
8.6. Granting a license extension based upon an academic analysis of potential degradation for 80 years of operation must not allow exceedances to be glossed over by future NRC waivers. When an energy corporation, like NextEra, exceeds its license extension plan, the NRC must commit to immediate plant closure.
- 9. Superpredator 9.1. Power plants that killed fish and other aquatic organisms were not regulated when the Point Beach reactors were commissioned and designed. There was no Environmental Protection Agency to promulgate regulations of cooling water
Page 22 of 27 intake from and heated water discharges to Lake Michigan. The EPA finally recognized the thermal pollution effects from atomic reactors after Point Beach was already in operation.
9.2. Nuclear reactors are the least efficient means of electric production because they discharge more heat into the environment than any other electricity production method. The so-called iconic image of two giant hyperbolic cooling towers frequently defines atomic power plants. Cooling towers are associated with nuclear power plants (NPPs) because NPPs have the lowest Carnot Cycle Efficiency of any form of electric generation, meaning that atomic power reactors create a disproportionately large amount of waste heat for the electricity they produce when compared to coal, oil, and natural gas.
9.3. Cooling towers exist for two reasons: first, to prevent the entrainment and death of fish eggs and larva in the high temperatures that exist within the PB condensers, and second, to ensure the tremendous amount of waste heat is not discharged directly into Lake Michigan, where it can significantly damage aquatic species like spawning fish, plankton, and other biota upon which all marine species are dependent for survival. The environmental damage caused by the waste heat from Point Beach to the Lake Michigan ecosystem is staggering, making it a superpredator.
9.4. More stringent environmental laws are now in place than in 1965 concerning the discharge of waste heat, and those laws are effectively applied to stop license renewal at other NPPs that are destroying their cooling water source with their waste heat.
9.5. Significant public and State opposition requiring the use of cooling towers as a condition for any 20-year operating extension has already occurred at three U.S.
atomic power reactor sites. Rather than spend the money necessary to retrofit those plants and install cooling towers as demanded by appropriate state water control authorities, the reactor owners chose to close the reactors.
Page 23 of 27 9.6. Oyster Creek, located on Barnegat Bay in New Jersey and owned by Exelon Corporation, applied successfully for a 20-year license extension from the NRC in 2009 but was denied the ability to discharge its waste heat into the Bay at the State permit level. Environmental groups, the State of New Jersey, and Exelon then negotiated an agreement that the plant would close by 2019 rather than operate until 2029 with a 20-year license extension, and Exelon would not install cooling towers for Oyster Creek. Exelon chose to give up the additional 10-years of operation of Oyster Creek and those profits rather than installing cooling towers.
9.7. On January 9, 2017, Entergy Corp, the State of New York, and environmental groups agreed to close the Indian Point Units 2 and 3 nuclear reactors in 2020 and 2021 rather than install cooling towers for Entergys proposed licensure venture. The negotiated settlement determined that Entergy would not build cooling towers during the last three and four years of proposed operation prior to Indian Points final shutdown, and Entergy would not seek to operate either reactor beyond 2021.
9.8. The situation at Point Beach Units 1 & 2 is strikingly similar to the failed attempts at Oyster Creek and Indian Point Units 2 & 3 to continue to operate without cooling towers despite significant environmental damage. When environmental groups, state environmental boards, and state attorneys general oppose 20-year license extensions, most nuclear power plants in the U.S. do not successfully receive the final 20-year license extension. Back fitting a cooling system that will mitigate ongoing environmental damage from nuclear power waste heat is critical to saving aquatic life, fishing, and survival of lakes, rivers, and ocean bays for other important community and financial purposes.
9.9. Nukes are the most thermodynamically inefficient way of producing electricity (Carnot efficiency). As such, they discharge an enormous amount of waste heat (hot water), and they consume a massive amount of cold water.
Page 24 of 27 9.10. The PB reactors were designed well before NEPA (the National Environmental Policy Act) when killing fish and other aquatic organisms were not a concern.
More modern designs require cooling towers.
9.11. Hundreds of millions of gallons of cold lake water containing fish, millions of fish larva, and other aquatic organisms are removed from the lake, heated by 30 degrees in the condenser, and killed each day; hence PB is a superpredator.
9.12. Additionally, abnormally hot chemically treated water is discharged back into the lake every day, allowing non-native species that thrive on warmer water to invade Point Beach environs and multiply in Lake Michigan.
9.13. Other aging nukes were forced to install cooling towers to continue past their original 40-year licensure. Diablo Canyon, Oyster Creek, Indian Point, others and chose to close rather than protect the environment.
9.14. There is a solution to save the aquatic biome of Lake Michigan. Require NextEra to install cooling towers for the two Point Beach atomic reactors.
- 10. Cost Of Alternatives 10.1. The economic case presented by NextEra PB in the Environmental Reports to justify its continued operation is flawed.
10.2. Due to competitive pressures from renewable and sustainable energy, old operating nuclear plants no longer produce electricity at competitive prices.
10.3. While building new nuclear plants costs tens of billions of dollars, old nuclear plants like PB have almost no market value. Most recently, Entergy sold its 838 MWe Fitzpatrick nuclear plant in upstate New York to Exelon. The sale price was $110M, which included fresh nuclear fuel, 600 trained employees, and the
Page 25 of 27 transfer of hundreds of millions of dollars to Exelon from the Fitzpatrick decommissioning fund.18 Fitzpatrick was given away.
10.4. Even if the initial cost to build an atomic plant is zero, the operating cost (salaries, fuel, repairs) is more expensive than the renewable alternatives. As Amory Lovins frequently notes:
Most U.S. nuclear power plants cost more to run than they earn. Globally, the World Nuclear Industry Status Report 2019 documents the nuclear enterprises slow-motion commercial collapsedying of an incurable attack of market forces. Yet in America, strong views are held across the political spectrum on whether nuclear power is essential or merely helpful in protecting the Earths climateand both those views are wrong. In fact, building new reactors, or operating most existing ones, makes climate change worse compared with spending the same money on more-climate-effective ways to deliver the same energy services. Those who state as fact that rejecting (more precisely, declining to bail out) nuclear energy would make carbon reduction much harder are in good company, but are mistaken Nuclear owners strive to beat coal and gas while their allies often disparage or suppress renewables. Yet most US nuclear plants are uneconomic just to run, so many are closing. To keep milking those old assets instead, their powerful owners seek and often get multi-billion-dollar bailouts from malleable state legislatures for about a tenth of the nuclear fleet so far, postponing the economic reckoning by shooting the market messenger.19 10.5. Because PB has entered into a very favorable power purchase agreement for itself and NextEra with the State of Wisconsin, Wisconsin ratepayers subsidize the Point Beach reactors.
10.6. Point Beachs Environmental Report ignores the option of replacing the reactors with wind turbines, whose total cost (install/operate) is much lower than the price just to continue to operate the Point Beach reactors. Additionally, installing wind power would be much safer for the environment and surrounding 18 https://www.bizjournals.com/albany/news/2016/08/09/entergy-selling-upstate-nuclear-power-plant-for.html 19 https://www.forbes.com/sites/amorylovins/2019/11/18/does-nuclear-power-slow-or-speed-climate-change/?sh=7b7c0a27506b
Page 26 of 27 communities rather than continuing to operate old aging and unsafe atomic reactors way past the time they were designed to run.
10.7. Thus, PB's continued operation will increase the cost of power to consumers compared to if it were to be replaced by renewables.
10.8. PBs Environmental Report ignores the existing transmission lines emanating from the current facility that provides a significant economic incentive to build local wind farms.
10.9. While closing PB will involve job changes for the PB staff, the staff has the correct skill set such that the new robust wind industry will provide them with jobs if they choose to remain in the electric generation field and want to stay locally.
10.10. Wind farms to replace PB will provide economic incentives for struggling farmers through yearly payments to use their land. This incentive to local farmers more than offsets the effect of Point Beach's closure on the local community.
10.11. Wind farms create taxable assets to offset most of the taxes paid by the NextEra facilities.
10.12. Additional construction jobs will be created for half a decade as Point Beach is decommissioned and dismantled.
10.13. Electric rates in Wisconsin will be lower if renewable alternatives replace PB.
10.14. Replacing an atomic facility with renewables has already begun to happen at a recently closed nuclear reactor owned by NextEra in Iowa. In an article entitled Huge solar farm planned for decommissioned Duane Arnold nuclear plant site, the Iowa Gazette outlines NextEras plans to replace the aging nuclear plant with a 3,500-acre solar farm.
Page 27 of 27 For more than four decades, the name of former Cedar Rapids utility executive Duane Arnold has been synonymous with nuclear power in Iowa. Now it could have a new connotation: a massive solar energy project planned for 2023 near the now-idle Duane Arnold Energy Center It is expected to produce up to 690 megawatts of solar energy even more than the single-unit nuclear plant generated.20
- 11. In my opinion, closing NextEra Point Beach and installing renewable generation like wind and solar by using PBs existing transmission lines will lower electric rates in Wisconsin, create jobs, increase farmers' income, maintain the tax base, and create a more viable future for local communities.
-END-Attachments: - Curriculum Vitae I declare under penalty of perjury that the preceding is true and correct.
Executed this 23rd day, March 2021 in Charleston, South Carolina
__________/s/_____________________
Arnold Gundersen, Chief Engineer, Fairewinds Associates, Inc MENE [Master Engineering Nuclear Engineering], RO [Reactor Operator]
Arnold Gundersen, Curriculum Vitae Chief Engineer, Fairewinds Associates, Inc March 2021 Education and Training ME NE Master of Engineering Nuclear Engineering Rensselaer Polytechnic Institute, 1972 U.S. Atomic Energy Commission Fellowship Thesis: Cooling Tower Plume Rise BS NE Bachelor of Science Nuclear Engineering Rensselaer Polytechnic Institute, Cum Laude, 1971 James J. Kerrigan Scholar RO Licensed Reactor Operator, U.S. Atomic Energy Commission, License # OP-3014 Patents Energy Absorbing Turbine Missile Shield - U.S. Patent # 4,397,608 - 8/9/1983 Honors U.S. Atomic Energy Commission Fellowship, 1972 B.S. Degree, Cum Laude, RPI, 1971, 1st in nuclear engineering class Tau Beta Pi (Engineering Honor Society), RPI, 1969 - 1 of 5 in sophomore class of 700 James J. Kerrigan Scholar 1967-1971 Publicly commended to U.S. Senate by NRC Chairman, Ivan Selin, in May 1993 - It is true...everything Mr. Gundersen said was absolutely right; he performed quite a service.
Expert Qualifications - including and not limited to:
- Chief Engineer, Fairewinds Associates, Inc, 2003 to present
- Nuclear Engineering, Safety, and Reliability Expert
- Federal and Congressional hearing testimony, Expert Witness testimony, Public Utility Commission Testimony, state legislative hearings, community stakeholder expert witness
- Former Senior Vice President Nuclear Licensee
- Former Licensed Reactor Operator
- Atomic Energy Commission Fellow
- 50 years of nuclear industry experience and oversight Publications Co-author Radioactive Isotopes Measured at Olympic and Paralympic Venues in Fukushima Prefecture and Tokyo, Japan, Journal of Environmental Engineering Science Volume 38, Number 2, 2021, Mary Ann Liebert, Inc., DOI: 10.1089/ees.2020.0139 Co-author with corresponding author Dr. Marco Paul Johann Kaltofen, Department of Physics, Worcester Polytechnic Institute (WPI), Worcester, MA, USA and Maggie Gundersen, Founder of Fairewinds Energy Education, Charleston, SC, USA.
Page 2 of 20 Co-author -- Science of the Total Environment (STOTEN) published a peer-reviewed article entitled: Radioactively-hot particles detected in dusts and soils from Northern Japan by combination of gamma spectrometry, autoradiography, and SEM/EDS analysis and implications in radiation risk assessment. Co-authored with Dr. Marco Kaltofen, Worcester Polytechnic Institute (WPI), it details the analysis of radioactively hot particles collected in Japan following the Fukushima Dai-ichi meltdowns.
Published Lecture -- The Lessons of the Fukushima Daiichi Nuclear Accident published in the International Symposium on the Truth of Fukushima Nuclear Accident and the Myth of Nuclear Safety, August 30, 2012 University of Tokyo, Iwanami Shoten Publishers, Tokyo, Japan Published Lecture -- Crisis Without End: The Medical and Ecological Consequences of the Fukushima Nuclear Catastrophe, from the Symposium at the New York Academy of Medicine, The New Press, 2014, Chapter 12, What Did They Know and When Author -- The Echo Chamber: Regulatory Capture and the Fukushima Daiichi Disaster, Lessons from Fukushima, February 27, 2012, Greenpeace International Author -- Fukushima Daiichi: Truth and The Way Forward, Shueisha Publishing, February 17, 2012, Tokyo, Japan.
Co-author DOE Decommissioning Handbook, First Edition, 1981-1982, invited author.
Presentations, Events, & Media (located @ end of CV)
Committee Memberships Current member and founding member, Board of Directors, Fairewinds Energy Education Corp, 501(c)3 Vermont Yankee Public Oversight Panel, appointed 2008 by President Pro-Tem Vermont Senate National Nuclear Safety Network - Founding Board Member Three Rivers Community College - Nuclear Academic Advisory Board Connecticut Low Level Radioactive Waste Advisory Committee - 10 years, founding member Radiation Safety Committee, NRC Licensee - founding member ANSI N-198, Solid Radioactive Waste Processing Systems University Fellowship, Teaching, and Academic Administration University of Vermont Community Research Fellow, appointed January 2016 through 2018 Community College of Vermont - Mathematics Professor - 2007 through Spring 2013 Rensselaer Polytechnic Institute (RPI) - Advanced Nuclear Reactor Physics Lab Expert Witness Testimony and Nuclear Engineering Analysis and Consulting Before The United States Of America Nuclear Regulatory Commission Office of The Secretary Declaration Of Arnold Gundersen To Support The Motion To Reopen Proceeding And Request To Amend Contention By The Blue Ridge Environmental Defense League And Its Chapter Concerned Citizens Of Shell Bluff Regarding Southern Nuclear Operating Companys Request For A License Amendment And Exemption For Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements, Lar-20-001, December 7, 2020. In the Matter of the Southern Nuclear Operating Company License
Page 3 of 20 Amendment Application for Combined License NPF-91 at the Vogtle Electric Generating Plant Unit
- 3. Docket No. 52-025-LA-3 Before The United States Of America Nuclear Regulatory Commission Office of The Secretary In the Matter of the Southern Nuclear Operating Company License Amendment Application for Combined License NPF-91 at the Vogtle Electric Generating Plant Unit 3. Docket No. 52-025-LA-3 Declaration of Arnold Gundersen to Support The Petition For Leave To Intervene And Request For Hearing By The Blue Ridge Environmental Defense League And Its Chapter Concerned Citizens Of Shell Bluff Regarding Southern Nuclear Operating Companys Request For A License Amendment And Exemption For Unit 3 Auxiliary Building Wall 11 Seismic Gap Requirements, Lar-20-001 Before the State of Vermont Public Utilities Commission, Surrebuttal Testimony of Arnold Gundersen. December 1, 2017. VTPUC Docket 8880, Joint Petition of NorthStar Decommissioning Holdings, LLC.
Before the State of Vermont Public Utilities Commission, Testimony of Arnold Gundersen Supporting the New England Coalition: An Evaluation of The Financial Risks to Vermont In the Proposed Sale of The Entergy Nuclear Vermont Yankee Power Plant Site to NorthStar Decommissioning Holdings, LLC. August 30, 2017. VTPUC Docket 8880, Joint Petition of NorthStar Decommissioning Holdings, LLC.
Before the United States District Court Northern District Of Illinois, Steve Lawson And Darla Lawson, Other Similar Situated Individuals, Plaintiffs, Vs. General Electric, And Does 1-200, Defendants. Expert Witness Report by Arnold Gundersen, Prepared for Plaintiffs Attorney: Charles A. Bonner, Esq. Sb# 85413. May 25, 2017. Analysis of radiation exposure to GE journeyman welder.
Before the Public Utilities Commission of The State of California - January 27, 2017 - Prepared Direct Testimony of Arnold Gundersen of Fairewinds Associates, Inc., For San Luis Obispo Mothers for Peace regarding the: Application of Pacific Gas and Electric Company for Approval of the Retirement of Diablo Canyon Power Plant, Implementation of the Joint Proposal, and Recovery of Associated Costs Through Proposed Ratemaking Mechanisms Application 16-08-006 (Filed August 11, 2016)
Nuclear Regulatory Commission Before the Secretary - May 2, 2016, - Declaration of Arnold Gundersen To Support the Petition for Leave to Intervene And Request For Hearing By The Blue Ridge Environmental Defense League Regarding Southern Nuclear Operating Companys Vogtle Electric Generating Plant Units 3 And 4 Request For License Amendment And Exemption:
Containment Hydrogen Igniter Changes (LAR-15-003)
Fairewinds Energy Education Report Submitted to NRC in Response to an Advance Notice of Proposed Rulemaking for Regulatory Improvements for Decommissioning Power Reactors: -
March 17, 2016, The Nationwide Failures of Decommissioning Regulation: Decommissioning Trust Funds or Slush Funds?
Fairewinds Energy Education Report Submitted to NRC for Public Comment to Staff Regarding the Decommissioning of the Vermont Yankee Atomic Reactor - March 23, 2015, Vermont Yankees Decommissioning as an Example of Nationwide Failures of Decommissioning Regulation NRC Before the Atomic Safety and Licensing Board (ASLB) - December 1, 2014, Gundersen Declaration Palisades Embrittlement, Docket No. 50-255, Entergy, Palisades, Petition to Intervene
Page 4 of 20 and for A Public Adjudication Hearing of Entergy License Amendment Request for Authorization to Implement 10 CFR §50.61a, Alternate Fracture Toughness Requirements For Protection Against Pressurized Thermal Shock Events.
NRC Before the Commission - November 6, 2014, Second Supplemental Declaration of Arnold Gundersen, In the Matter of Florida Power & Light Co., Docket No. 50-389, St. Lucie Plant, Unit 2.
NRC Atomic Safety and Licensing Board (ASLB) - October 10, 2014 - Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Gundersen Affidavit Supporting Friends of the Earths Petition to Intervene: In the matter of Pacific Gas & Electric Company Docket No. 50-275-LR & Docket No.
50-323-LR, License Renewal Application.
NRC Hearing Request - Declaration of Arnold Gundersen Supporting Hearing Request, March 10, 2014 - retained by Southern Alliance for Clean Energy (SACE) in the matter of Florida Power &
Light Co., Docket No. 50-389, St. Lucie Plant, Unit 2 NRC ASLB Proceeding Fermi Unit 3 52-033-COL - October 30, 2013 - Retained by Don't Waste Michigan, Beyond Nuclear et al, Oral Expert Witness Testimony regarding Contention 15: Quality Assurance.
State of Utah Seventh District Court of Emory County - September 25, 2013 - Retained by HEAL Utah et al as an expert witness testifying on cooling tower consumptive use of water for a proposed nuclear power plant owned by Blue Castle Holdings and located on the Green River.
Defendants were Kane County Water Conservancy District.
Canadian Nuclear Safety Commission - May 29-30, 2013 - Retained by Durham Nuclear Awareness to present expert witness testimony in hearings regarding the proposed life extension for the Pickering Nuclear Station owned Ontario Power Generation.
Nuclear Regulatory Commission - May 30, 2013 - Expert witness report Before the Secretary NRC in the Matter of Detroit Edison Nuclear Power Station: Rebuttal Testimony of Arnold Gundersen Supporting of Intervenors Contention 15: DTE COLA Lacks Statutorily Required Cohesive QA Program. Retained by Dont Waste Michigan, Beyond Nuclear et al.
Nuclear Regulatory Commission - May 20, 2013 - Expert witness report Before the Secretary NRC in the Matter of Davis Besse Nuclear Power Station: Expert Witness Report of Arnold Gundersen to Support the Petition for Leave to Intervene and Request for Hearing by Beyond Nuclear, Citizens Environment Alliance Southwest Ontario Canada, Dont Waste Michigan, and The Sierra Club.
Retained by Beyond Nuclear, Citizens Environment Alliance Southwest Ontario Canada, Dont Waste Michigan, and The Sierra Club.
Nuclear Regulatory Commission - May 6, 2013 - Expert witness report Before the Secretary NRC:
Expert Witness Report of Arnold Gundersen to Support the Petition for Leave to Intervene and Request for Hearing by The Blue Ridge Environmental Defense League, Bellefonte Efficiency and Sustainability Team, And Mothers Against Tennessee River Radiation. Retained by BREDL et al.
Nuclear Regulatory Commission - April 30, 2013 - Expert witness report to Atomic Safety and Licensing Board: Testimony of Arnold Gundersen Supporting of Intervenors Contention 15: DTE
Page 5 of 20 Cola Lacks Statutorily Required Cohesive QA Program. Retained by Dont Waste Michigan, Beyond Nuclear et al.
Canadian Nuclear Safety Commission (CNSC) - April 29, 2013 - Expert witness report to Canadian Nuclear Safety Commission (CNSC): Analysis of The Relicensing Application for Pickering Nuclear Generating Station. Retained by Durham Nuclear Awareness.
Nuclear Regulatory Commission - January 16, 2013 - Expert witness presentation to NRC Petition Review Board: 2.206 Presentation San Onofre Units 2 and 3 Replacement Steam Generators Meeting with Petitioner Friends of the Earth, Requesting Enforcement Action Against Southern California Edison Under 10 CFR 2.206 Expert Witness Report for Friends of The Earth - July 11, 2012 - San Onofres Steam Generators:
Significantly Worse Than All Others Nationwide, Fairewinds Associates, Inc Expert Witness Report for Friends of the Earth - May 15, 2012 - San Onofre Steam Generator Failures Could Have Been Prevented, Fairewinds Associates, Inc Expert Witness Report for Friends of the Earth - April 10, 2012 - San Onofre Cascading Steam Generator Failures Created by Edison: Imprudent Design and Fabrication Decisions Caused Leaks, Fairewinds Associates, Inc Expert Witness Report for Friends of the Earth - March 27, 2012 - Steam Generator Failures at San Onofre: The Need for A Thorough Root Cause Analysis Requires No Early Restart, Fairewinds Associates, Inc Expert Witness Report for Greenpeace - February 27, 2012 - Lessons from Fukushima: The Echo Chamber Effect, Fairewinds Associates, Inc Nuclear Regulatory Commission - December 21, 2011 - Expert witness report to Atomic Safety and Licensing Board: Prefiled Direct Testimony of Arnold Gundersen Regarding Consolidated Contention RK-EC-3/CW-EC-1 (Spent Fuel Pool Leaks)
New York State Department of Environmental Conservation - November 15-16, 2011 - Expert witness report for Riverkeeper: hearing testimony regarding license extension application for Indian Point Units 2 and 3 - contention: tritium in the groundwater.
Nuclear Regulatory Commission - November 10, 2011 - Expert witness report entitled: Fukushima and the Westinghouse-Toshiba AP1000, A Report for the AP1000 Oversight Group by Fairewinds Associates, Inc, and Video. Submitted to NRC by the AP1000 Oversight Group.
Nuclear Regulatory Commission - October 7, 2011 - Testimony to the NRC Petition Review Board Re: Mark 1 Boiling Water Reactors, Petition for NRC to shut down all BWR Mark 1 nuclear power plants due to problems in containment integrity in the Mark 1 design.
Page 6 of 20 New York State Department of Environmental Conservation - October 4, 2011 - Prefiled Rebuttal Testimony of Arnold Gundersen On Behalf of Petitioners Riverkeeper, Inc., Scenic Hudson, Inc., And Natural Resources Defense Council, Inc. To The Direct Testimony of Matthew J. Barvenik (Senior Principal GZA Geoenvironmental, Inc.) Regarding Radiological Materials Southern Alliance for Clean Energy (SACE) submission to TVA Board of Directors - August 3, 2011-Expert witness report entitled: The Risks of Reviving TVAs Bellefonte Project, and Video prepared for the Southern Alliance for Clean Energy (SACE).
New York State Department of Environmental Conservation, July 22, 2011 - Prefiled Direct Testimony of Arnold Gundersen On Behalf of Petitioners Riverkeeper, Inc., Scenic Hudson, Inc.,
And Natural Resources Defense Council, Inc. Regarding Radiological Materials Nuclear Regulatory Commission - May 10, 2011 - Comment to the proposed rule on the AP1000 Design Certification Amendment Docket ID NRC-2010-0131 As noticed in the Federal Register on February 24, 2011 Retained by Friends of the Earth as Expert Witness.
Nuclear Regulatory Commission - May 10, 2011 - Comment to the proposed rule on the AP1000 Design Certification Amendment Docket ID NRC-2010-0131 As noticed in the Federal Register on February 24, 2011 Retained by Friends of the Earth as Expert Witness.
NRC Advisory Committee on Reactor Safeguards (ACRS) - May 26, 2011 - Lessons learned from Fukushima and Containment Integrity on the AP1000.
Vermont Energy Cooperative (VEC) - April 26, 2011 - Presentation to the Vermont Energy Cooperative Board of Directors, Vermont Yankee - Is It Reliable for 20 more years?
Vermont State Nuclear Advisory Panel (VSNAP) - February 22, 2011 - Testimony and presentation entitled the Vermont Yankee Public Oversight Panel Supplemental Report regarding management issues at the Vermont Yankee Nuclear Power Plant to the reconvened Vermont State Nuclear Advisory Panel.
Vermont State Legislature Senate Committee on Natural Resources and Energy - February 8, 2011.
Testimony: Vermont Yankee Leaks and Implications. (http://www.leg.state.vt.us/jfo/envy.aspx)
Vermont State Legislature - January 26, 2011 - House Committee on Natural Resources and Energy, and Senate Committee on Natural Resources and Energy - Testimony regarding Fairewinds Associates, Incs report: Decommissioning the Vermont Yankee Nuclear Power Plant and Storing Its Radioactive Waste (http://www.leg.state.vt.us/jfo/envy.aspx). Additional testimony was also given regarding the newest radioactive isotopic leak at the Vermont Yankee nuclear power plant.
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - Decommissioning the Vermont Yankee Nuclear Power Plant and Storing Its Radioactive Waste January 2011. (http://www.leg.state.vt.us/jfo/envy.aspx).
Page 7 of 20 U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards (NRC-ACRS)
AP1000 Sub-Committee - Nuclear Containment Failures: Ramifications for the AP1000 Containment Design, Supplemental Report submitted December 21, 2010.
(http://fairewinds.com/reports)
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - Reliability Oversight Entergy Nuclear Vermont Yankee, December 6, 2010.
Discussion regarding the leaks at Vermont Yankee and the ongoing monitoring of those leaks and ENVYs progress addressing the 90-items identified in Act 189 that require remediation.
(http://www.leg.state.vt.us/jfo/envy.aspx).
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contention Regarding Consumptive Water Use at Dominion Powers Newly Proposed North Anna Unit 3 Pressurized Water Reactor in the matter of Dominion Virginia Power North Anna Power Station Unit 3 Docket No.52-017 Combined License Application ASLBP#08-863-01-COL, October 2, 2010.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues New Contention Regarding AP1000 Containment Integrity on the Vogtle Nuclear Power Plant Units 3 And 4 in the matter of the Southern Nuclear Operating Company Vogtle Electric Generating Plant, Units 3&4 Combined License Application, Docket Nos. 52-025-COL and 52-026-COL and ASLB No. 09-873-01-COL-BD01, August 13, 2010.
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - July 26, 2010 - Summation for 2009 to 2010 Legislative Year for the Joint Fiscal Committee Reliability Oversight Entergy Nuclear Vermont Yankee (ENVY) Fairewinds Associates 2009-2010. This summary includes an assessment of ENVYs progress (as of July 1, 2010) toward meeting the milestones outlined by the Act 189 Vermont Yankee Public Oversight Panel in its March 2009 report to the Legislature, the new milestones that have been added since the incident with the tritium leak and buried underground pipes, and the new reliability challenges facing ENVY, Entergy, and the State of Vermont. (http://www.leg.state.vt.us/jfo/envy.aspx)
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions in the matter of Dominion Virginia Power North Anna Station Unit 3 Combined License Application, Docket No.52-017, ASLBP#08-863-01-COL, July 23, 2010.
Florida Public Service Commission (FPSC)
Licensing and construction delays due to problems with the newly designed Westinghouse AP1000 reactors in Direct Testimony in Re: Nuclear Plant Cost Recovery Clause by The Southern Alliance for Clean Energy (SACE), FPSC Docket No. 100009-EI, July 8, 2010.
U.S. Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards (NRC-ACRS)
AP1000 Sub-Committee - Presentation to ACRS regarding design flaw in AP1000 Containment -
June 25, 2010 Power Point Presentation: http://fairewinds.com/content/ap1000-nuclear-design-flaw-addressed-to-nrc-acrs.
Page 8 of 20 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Second Declaration of Arnold Gundersen Supporting Supplemental Petition of Intervenors Contention 15: DTE COLA Lacks Statutorily Required Cohesive QA Program - June 8, 2010.
NRC Chairman Gregory Jaczko, ACRS, Secretary of Energy Chu, and the White House Office of Management and Budget - AP1000 Containment Leakage Report Fairewinds Associates -
Gundersen, Hausler, 4-21-2010. This report, commissioned by the AP1000 Oversight Group, analyzes a potential flaw in the containment of the AP1000 reactor design.
Vermont State Legislature House Committee on Natural Resources and Energy - April 5, 2010
- Testified to the House Committee on Natural Resources and Energy - regarding discrepancies in Entergys TLG Services decommissioning analysis. See Fairewinds Cost Comparison TLG Decommissioning (http://www.leg.state.vt.us/jfo/envy.aspx).
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - February 22, 2010 - The Second Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding buried pipe and tank issues at Entergy Nuclear Vermont Yankee and Entergy proposed Enexus spinoff. See two reports: Fairewinds Associates 2nd Quarterly Report to JFC and Enexus Review by Fairewinds Associates.
(http://www.leg.state.vt.us/jfo/envy.aspx).
Vermont State Legislature Senate Natural Resources - February 16, 2010 - Testified to Senate Natural Resources Committee regarding causes and severity of tritium leak in unreported buried underground pipes, status of Enexus spinoff proposal, and health effects of tritium.
Vermont State Legislature Senate Natural Resources - February 10, 2010 - Testified to Senate Natural Resources Committee regarding causes and severity of tritium leak in unreported buried underground pipes. http://www.youtube.com/watch?v=36HJiBrJSxE Vermont State Legislature Senate Finance - February 10, 2010 - Testified to Senate Finance Committee regarding A Chronicle of Issues Regarding Buried Tanks and Underground Piping at VT Yankee. (http://www.leg.state.vt.us/jfo/envy.aspx).
Vermont State Legislature House Committee on Natural Resources and Energy - January 27, 2010 -
A Chronicle of Issues Regarding Buried Tanks and Underground Piping at VT Yankee.
(http://www.leg.state.vt.us/jfo/envy.aspx).
Submittal to Susquehanna River Basin Commission, by Eric Epstein - January 5, 2010 -
Expert Witness Report of Arnold Gundersen Regarding Consumptive Water Use of the Susquehanna River by The Proposed PPL Bell Bend Nuclear Power Plant in the Matter of RE: Bell Bend Nuclear Power Plant Application for Groundwater Withdrawal Application for Consumptive Use BNP-2009-073.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Declaration of Arnold Gundersen Supporting Supplemental Petition of Intervenors Contention 15:
Detroit Edison COLA Lacks Statutorily Required Cohesive QA Program, December 8, 2009.
U.S. NRC Region III Allegation Filed by Missouri Coalition for the Environment - Expert Witness Report entitled: Comments on the Callaway Special Inspection by NRC Regarding the May 25, 2009
Page 9 of 20 Failure of its Auxiliary Feedwater System, November 9, 2009.
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - Oral testimony given to the Vermont State Legislature Joint Fiscal Committee October 28, 2009. See report: Quarterly Status Report - ENVY Reliability Oversight for JFO (http://www.leg.state.vt.us/jfo/envy.aspx).
Vermont State Legislature Joint Fiscal Committee Legislative Consultant Regarding Entergy Nuclear Vermont Yankee - The First Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding reliability issues at Entergy Nuclear Vermont Yankee, issued October 19, 2009.
See report: Quarterly Status Report - ENVY Reliability Oversight for JFO (http://www.leg.state.vt.us/jfo/envy.aspx).
Florida Public Service Commission (FPSC) - Gave direct oral testimony to the FPSC in hearings in Tallahassee, FL, September 8 and 10, 2009 in support of Southern Alliance for Clean Energy (SACE) contention of anticipated licensing and construction delays in newly designed Westinghouse AP 1000 reactors proposed by Progress Energy Florida and Florida Power and Light (FPL).
Florida Public Service Commission (FPSC) - NRC announced delays confirming my original testimony to FPSC detailed below. My supplemental testimony alerted FPSC to NRC confirmation of my original testimony regarding licensing and construction delays due to problems with the newly designed Westinghouse AP 1000 reactors in Supplemental Testimony in Re: Nuclear Plant Cost Recovery Clause by The Southern Alliance for Clean Energy, FPSC Docket No. 090009-EI, August 12, 2009.
Florida Public Service Commission (FPSC) - Licensing and construction delays due to problems with the newly designed Westinghouse AP 1000 reactors in Direct Testimony in Re: Nuclear Plant Cost Recovery Clause by The Southern Alliance for Clean Energy (SACE), FPSC Docket No.
090009-EI, July 15, 2009.
Vermont State Legislature Joint Fiscal Committee Expert Witness Oversight Role for Entergy Nuclear Vermont Yankee (ENVY) - Appointment from July 2009 to May 2010. Contracted by the Joint Fiscal Committee of the Vermont State Legislature as an expert witness to oversee the compliance of ENVY to reliability issues uncovered during the 2009 legislative session by the Vermont Yankee Public Oversight Panel of which I was appointed a member along with former NRC Commissioner Peter Bradford for one year from July 2008 to 2009. At the time, Entergy Nuclear Vermont Yankee (ENVY) was under review by Vermont State Legislature to determine if it should receive a Certificate for Public Good (CPG) to extend its operational license for another 20-years.
Vermont was the only state in the country that had legislatively created the CPG authorization for a nuclear power plant. Act 160 was passed to ascertain ENVYs ability to run reliably for an additional 20 years.
U.S. Nuclear Regulatory Commission - Expert Witness Declaration regarding Combined Operating License Application (COLA) at North Anna Unit 3 Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions (June 26, 2009).
U.S. Nuclear Regulatory Commission - Expert Witness Declaration regarding Through-wall Penetration of Containment Liner and Inspection Techniques of the Containment Liner at Beaver Valley Unit 1 Nuclear Power Plant Declaration of Arnold Gundersen Supporting Citizen Powers
Page 10 of 20 Petition (May 25, 2009).
U.S. Nuclear Regulatory Commission - Expert Witness Declaration regarding Quality Assurance and Configuration Management at Bellefonte Nuclear Plant Declaration of Arnold Gundersen Supporting Blue Ridge Environmental Defense Leagues Contentions in their Petition for Intervention and Request for Hearing, May 6, 2009.
Pennsylvania Statehouse - Expert Witness Analysis presented in formal presentation at the Pennsylvania Statehouse, March 26, 2009 regarding actual releases from Three Mile Island Nuclear Accident. Presentation may be found at: http://www.tmia.com/march26 Vermont Legislative Testimony and Formal Report for 2009 Legislative Session - As a member of the Vermont Yankee Public Oversight Panel, I spent almost eight months examining the Vermont Yankee Nuclear Power Plant and the legislatively ordered Comprehensive Vertical Audit. Panel submitted Act 189 Public Oversight Panel Report March 17, 2009 and oral testimony to a joint hearing of the Senate Finance and House Committee on Natural Resources and Energy March 19, 2009. http://www.leg.state.vt.us/JFO/Vermont%20Yankee.htm Finestone v Florida Power & Light Company (FPL) (11/2003 to 12/2008) Federal Court - Plaintiffs Expert Witness in United States District Court for the Southern District of Florida. Retained by Plaintiffs Attorney Nancy LaVista, from Lytal, Reiter, Fountain, Clark, Williams, West Palm Beach, FL. Case# 06-11132-E. This case involved two plaintiffs in cancer cluster of 42 families alleging that illegal radiation releases from nearby nuclear power plant caused childrens cancers. Production request, discovery review, preparation of deposition questions and attendance at Defendants experts for deposition, preparation of expert witness testimony, preparation for Daubert Hearings, ongoing technical oversight, source term reconstruction and appeal to Circuit Court.
U.S. Nuclear Regulatory Commission Advisory Committee Reactor Safeguards (NRC-ACRS) -
Expert Witness providing oral testimony regarding Millstone Point Unit 3 (MP3) Containment issues in hearings regarding the Application to Uprate Power at MP3 by Dominion Nuclear, Washington, and DC. (July 8-9, 2008).
Appointed by President Pro-Tem of Vermont Senate Shumlin (later elected as Vermont Governor) to Legislatively Authorized Nuclear Reliability Public Oversight Panel - To oversee Comprehensive Vertical Audit of Entergy Nuclear Vermont Yankee (Act 189) and testify to State Legislature during 2009 session regarding operational reliability of ENVY in relation to its 20-year license extension application. (July 2, 2008 to present).
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -Expert Witness providing testimony regarding Pilgrim Watchs Petition for Contention 1 Underground Pipes (April 10, 2008).
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Expert Witness supporting Connecticut Coalition Against Millstone in Its Petition for Leave to Intervene, Request for Hearing, And Contentions Against Dominion Nuclear Connecticut Inc.s Millstone Power Station Unit 3 License Amendment Request for Stretch Power Uprate (March 15, 2008).
Page 11 of 20 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Expert Witness supporting Pilgrim Watchs Petition for Contention 1: specific to issues regarding the integrity of Pilgrim Nuclear Power Stations underground pipes and the ability of Pilgrims Aging Management Program to determine their integrity. (January 26, 2008).
Vermont State House - 2008 Legislative Session -
! House Committee on Natural Resources and Energy - Comprehensive Vertical Audit: Why NRC Recommends a Vertical Audit for Aging Plants Like Entergy Nuclear Vermont Yankee (ENVY)
! House Committee on Commerce - Decommissioning Testimony Vermont State Senate - 2008 Legislative Session -
! Senate Finance - testimony regarding Entergy Nuclear Vermont Yankee Decommissioning Fund
! Senate Finance - testimony on the necessity for a Comprehensive Vertical Audit (CVA) of Entergy Nuclear Vermont Yankee
! House Committee on Natural Resources and Energy - testimony regarding the placement of high-level nuclear fuel on the banks of the Connecticut River in Vernon, VT U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) - MOX Limited Appearance Statement to Judges Michael C. Farrar (Chairman), Lawrence G. McDade, and Nicholas G. Trikouros for the Petitioners: Nuclear Watch South, the Blue Ridge Environmental Defense League, and Nuclear Information & Resource Service in support of Contention 2:
Accidental Release of Radionuclides, requesting a hearing concerning faulty accident consequence assessments made for the MOX plutonium fuel factory proposed for the Savannah River Site.
(September 14, 2007).
Appeal to the Vermont Supreme Court (March 2006 to 2007) - Expert Witness Testimony in support of New England Coalitions Appeal to the Vermont Supreme Court Concerning: Degraded Reliability at Entergy Nuclear Vermont Yankee as a Result of the Power Uprate. New England Coalition represented by Attorney Ron Shems of Burlington, VT.
State of Vermont Environmental Court (Docket 89-4-06-vtec 2007) - Expert witness retained by New England Coalition to review Entergy and Vermont Yankees analysis of alternative methods to reduce the heat discharged by Vermont Yankee into the Connecticut River. Provided Vermont's Environmental Court with analysis of alternative methods systematically applied throughout the nuclear industry to reduce the heat discharged by nuclear power plants into nearby bodies of water and avoid consumptive water use. This report included a review of the condenser and cooling tower modifications.
U.S. Senator Bernie Sanders and Congressman Peter Welch (2007) - Briefed Senator Sanders, Congressman Welch and their staff members regarding technical and engineering issues, reliability and aging management concerns, regulatory compliance, waste storage, and nuclear power reactor safety issues confronting the U.S. nuclear energy industry.
State of Vermont Legislative Testimony to Senate Finance Committee (2006) - Testimony to the Senate Finance Committee regarding Vermont Yankee decommissioning costs, reliability issues, design life of the plant, and emergency planning issues.
Page 12 of 20 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board (NRC-ASLB) -
Expert witness retained by New England Coalition to provide Atomic Safety and Licensing Board with an independent analysis of the integrity of the Vermont Yankee Nuclear Power Plant condenser (2006).
U.S. Senators Jeffords and Leahy (2003 to 2005) - Provided the Senators and their staffs with periodic overview regarding technical, reliability, compliance, and safety issues at Entergy Nuclear Vermont Yankee (ENVY).
10CFR 2.206 filed with the Nuclear Regulatory Commission (July 2004) - Filed 10CFR 2.206 petition with NRC requesting confirmation of Vermont Yankee's compliance with General Design Criteria.
State of Vermont Public Service Board (April 2003 to May 2004) - Expert witness retained by New England Coalition to testify to the Public Service Board on the reliability, safety, technical, and financial ramifications of a proposed increase in power (called an uprate) to 120% at Entergys 31-year-old Vermont Yankee Nuclear Power Plant.
International Nuclear Safety Testimony - Ten Days advising the President of the Czech Republic (Vaclav Havel) and the Czech Parliament on their energy policy for the 21st century.
Nuclear Regulatory Commission (NRC) Inspector General (IG) - Assisted the NRC Inspector General in investigating illegal gratuities paid to NRC Officials by Nuclear Energy Services (NES)
Corporate Officers. In a second investigation, assisted the Inspector General in showing that materially false statements (lies) by NES corporate president caused the NRC to overlook important violations by this licensee.
State of Connecticut Legislature - Assisted in the creation of State of Connecticut Whistleblower Protection legal statutes.
Federal Congressional Testimony -
Publicly recognized by NRC Chairman, Ivan Selin, in May 1993 in his comments to U.S. Senate, It is true...everything Mr. Gundersen said was absolutely right; he performed quite a service.
Commended by U.S. Senator John Glenn, Chair NRC Oversight Committee for public - for testimony to NRC Oversight Committee PennCentral Litigation - Evaluated NRC license violations and materially false statements made by management of this nuclear engineering and materials licensee.
Three Mile Island Litigation - Evaluated unmonitored releases to the environment after accident, including containment breach, letdown system and blowout. Proved releases were 15 times higher than government estimate and subsequent government report.
Western Atlas Litigation - Evaluated neutron exposure to employees and license violations at this nuclear materials licensee.
Commonwealth Edison - In depth review and analysis for Commonwealth Edison to analyze the efficiency and effectiveness of all Commonwealth Edison engineering organizations, which support the operation of all of its nuclear power plants.
Page 13 of 20 Peach Bottom Reactor Litigation - Evaluated extended 28-month outage caused by management breakdown and deteriorating condition of plant.
Presentations, Events, & Media
- Three Mile Island (TMI) Presentations and Events, March 23 through March 27, 2019 o
A Legacy of Lies, PennState TMI 40th Commemoration Keynote, March 27, 2019, followed by 4-TV interviews, available on CSPAN o
NBC TV Andrea Mitchell Interview, filmed 2019-3-26, aired March 28, 2019 o
Presentation Pennsylvania State House Rotunda, Harrisburg, PA, March 25, 2019 o
TMI Survivors Banquet, Keynote and Q&A, March 23, 2019 o
Media Interviews with WHP 21 (CBS), WGAL (NBC), WHP 27 (ABC) o Keynote Harrisburg Historical Society, keynote, Harrisburg, Pennsylvania March 23, 2019
- The Fukushima Vogtle Connection, hosted by Georgia Wand and Nuclear Watch South, March 9, 2019
- Power Lines Documentary Premier at Emory University, Atlanta, GA, October 2018
- CCTV, Nuclear Free Future TV with host Margaret Harrington, Picking Up the Pieces from Atoms for Peace, May 10, 2018
- CCTV, Nuclear Free Future TV with host Margaret Harrington, Nuclear Update with Fairewinds Energy Education - March 10, 2018
- Chicago, NIRS meetings and group presentations November 28 to December 4, 2017
- Radio Interviews, November 2017: David Goodman, October 25, 2017; Project Censored with Mickey Huff, November 2017 Fukushima Prefecture, Japan, September 7-18, 2017, Arnie Gundersen and Dr. Marco Kaltofen, research and data review technical meeting with the Deputy Director General and the Senior Associate with the Japanese Atomic Energy Agency (JAEA). Trip to Japan was organized and funded by Fairewinds Energy Education.
CCTV, Nuclear Free Future TV with host Margaret Harrington, Fukushima, Three Mile Island, and Chernobyl, March 30, 2017 Radio Ecoshock, Alex Smith Interview, Nuclear Power Is Not a Climate Change Solution, January 26, 2017 38 Years and Five Meltdowns Later: The Real Lessons from TMI (Three Mile Island), March 25, 2017, keynote presentation hosted by Three Mile Island Alert, Harrisburg, PA Arnie Gundersen speaks with Margaret Prescod, March 14, 2017, Sojourner Truth Radio, Pacifica Radio on the Sixth-Year Commemoration of the Fukushima Daiichi nuclear power disaster.
Arnie Gundersen interviewed on Radiation Rattles Robot in Fukushima, Newsday - BBC World Service, High levels of nuclear radiation have forced a robot to cut short its investigations of the Fukushima reactor in Japan. The probes mission was to clean a passage to enable further robotic exploration, February 10, 2017.
Extreme Nuclear Dangers, Radio Ecoshock host Alex Smith interviews Arnie Gundersen, the relationship between the nuclear power industry and nuclear weapons development, February 2, 2017.
Page 14 of 20 Arnie Gundersen Appears on Project Censored with Dan Simon, Ted Rall, and Maggie Gundersen, November 27, 2016 Arnie Gundersen Appears on Solartopia's Green Power and Wellness Hour, November 16, 2016 Nuclear Power Is Not "Green Energy": It Is a Fount of Atomic Waste, Published in Truthout, November 14, 2016 Powerstruggle Sneak Preview Panel Discussion, Northampton, MA (October 23, 2016)
Brattleboro, VT (Nov 3, 2016), organized by Turning Tide Productions Is Solar Power in Nuclear Disaster Exclusion Zones Advisable? published in The Bulletin of the Atomic Scientists, September 15, 2016 CO2 Smokescreen Presentation, Montreal, Canada, invited speaker at the World Social Forum at the University of Quebec at Montreal (August 8, 2016) & McGill University, (August 10, 2016)
Gendai Business Online exclusive interview with Fairewinds Chief Engineer Arnie Gundersen entitled: American nuclear expert warns: "There is a possibility that now in Fukushima recontamination is occurring., June 14, 2016.
Seacoast Anti-Pollution League Annual Meeting, Seabrook, NH, organized by the Seacoast Anti-Pollution League, open to the public, May 16, 2016 Arnie Gundersen Appears on Project Censored with Medea Benjamin, March 30, 2016 Pilgrim Coalition Decommissioning Forum, Plymouth, MA, organized by the Pilgrim Coalition, March 23, 2016 Osaka Global Environment Forum 2016, in Osaka City, Japan, organized by Choetsu Kiko Association of Osaka and Friends of the Earth, February 27, 2016 Peace Forum Presentation, in Kobe City, Japan, organized by YMCA, UNICEF, and Kobe Cooperative, February 22, 2016 Nuclear and Human Beings after Fukushima Event, in Hiroshima City, Japan organized by Hiroshima YMCA, and Hiroshima Cooperative HANWA (Hiroshima Alliance for Nuclear Weapons Abolition), February 20, 2016 Peace Event at Jimmy Carter Civic Center, in Konu-town Miyoshi, Hiroshima, Japan organized by Peace Platform, February 17, 2016 Middlebury College Student Global Affairs Conference: Power and Protest, Middlebury, VT at Middlebury College, invited speaker for a student organized event, January 22, 2016 Ready for the Big One? Diablo Canyon Earthquake Vulnerability, San Luis Obispo, invited guest of the San Luis Obispo Mothers for Peace, December 2, 2015 Expect the Unexpected: Nuclear Power's Unlearned Lessons, California Polytechnic Institute, December 1, 2015 World in Danger: From Fukushima to California, University of California at Berkeley, in conversation with Joanna Macy, November 22, 2015 World in Danger: The Fukushima - California Connection, Point Reyes Station, in conversation with Mary Beth Brangan, November 21, 2015 World in Danger: Fukushima, Sonoma State University, in conversation with Majia Nadesan, November 18, 2015 Fukushimas Impact at Five Years, World Uranium Symposium 2015: Fukushima Workshop, April 2015, Quebec, Canada Did Tesla Just Kill Nuclear Power? May 1, 2015, Article written by journalist Jeff McMahon for Forbes Magazine that captures the excitement and buzz surrounding Tesla's big announcement and Arnie's auspicious speech Building New Nukes Would Make Global Warming Worse April 30, 2015, Presentation at Northwestern University, Chicago, IL
Page 15 of 20 Fairewinds Report: Vermont Yankees Decommissioning As An Example of Nationwide Failures of Decommissioning Regulation presented to the Senate Committee for Natural Resources and Energy April 22, 2015, Presentation Vermont Statehouse, Montpelier, VT An Economic Analysis of the Cost of Nuclear Power April 14, 2015, Presentation at the World Uranium Symposium, Quebec City, Quebec, Canada, Keynote Speaker Commemoration of Meltdown at Fukushima Daiichi: 4-Years Later March 11, 2015, Presentation to the House of Commons in London, England Should Nuclear Energy Be Expanded to Help Create a More Sustainable Future? November 20, 2014, Invited guest speaker in Debate at Hofstra University Radiation Knows No Borders August 2, 2014, Invited speaker at The Wave Conference, Life Chiropractic West, San Francisco, CA Thirty-Five Years and Five Meltdowns Later: The Real Lessons of Three Mile Island March 28, 2014, Three Mile Island at 35 (TMI@35) Symposium at Penn State, Harrisburg, PA, Keynote Speaker The Nuclear Renaissance? Is It Too Big To Fail? November 20, 2013, University North Carolina, Chapel Hill, NC.
Speaking Truth to Power October 22, 2013 - Clarkson University, Potsdam, NY The United States at A Crossroads: Two Futures October 17 2013, Global Forum, Waitsfield, Vermont A Road Less Taken: Energy Choices for the Future - October 16, 2013, Johnson State College, Johnson, Vermont.
Fukushima: Ongoing Lessons for Boston - October 9, 2013 - Boston, Massachusetts State House. Speakers were Arnie Gundersen, Former Japanese Prime Minister Naoto Kan, Former NRC Chair Gregory Jaczko, Former NRC Commissioner Peter Bradford, and Massachusetts State Senator Dan Wolf.
Fukushima: Ongoing Lessons for New York - October 8, 2013 - New York City 82nd Street YMCA. Speakers were Arnie Gundersen, Riverkeeper President Paul Galley, Former Japanese Prime Minister Naoto Kan, Former NRC Chair Gregory Jaczko, Former NRC Commissioner Peter Bradford, and Ralph Nader.
Fukushima: Ongoing Lessons for California - June 4, 2013 - New York City 82nd Street YMCA.
Speakers were Arnie Gundersen, Riverkeeper President Paul Galley, Former Japanese Prime Minister Naoto Kan, Former NRC Chair Gregory Jaczko, Former NRC Commissioner Peter Bradford, and Friends of the Earth Nuclear Campaigner Kendra Ulrich.
What Did They Know and When? Fukushima Daiichi Before and After the Meltdowns, Symposium: The Medical and Ecological Consequences of the Fukushima Nuclear Accident, The New York Academy of Medicine, New York City, NY, March 11, 2013 A Mountain of Waste 70 Years High, Presentation: Old and New Reactors, University of Chicago, December 1, 2012 Congressional Briefing September 20, 2012; invited by Representative Dennis Kucinich Presentations in Japan August/September 2012: Presentation at University of Tokyo (August 30, 2012), Presentation at Japanese Diet Building (members of the Japanese Legislature - August 31, 2012), Presentation to citizen groups in Niigata (September 1, 2012), Presentations to citizen groups in Kyoto (September 4, 2012), Presentation to Japanese Bar Association (September 2, 2012), and Presentation at the Tokyo Olympic Center (September 6, 2012)
Multi-media Opera: Curtain of Smoke, by Filmmaker Karl Hoffman, Composer Andrea Molino, and Dramatist Guido Barbieri, Rome, Italy (2012-5-21,22)
Curtain of Smoke Symposium (2012-5-21), with Dr. Sherri Ebadi 2004 Nobel Laureate
Page 16 of 20 The Italian National Press Club Rome (2012-5-21) with Dr. Sherri Ebadi 2004 Nobel Laureate:
the relationship between nuclear power and nuclear weapons, Radio 3 Rome (2012-5-21) Discussion of Three Mile Island and the triple meltdown at Fukushima Daiichi (Japan),
Sierra Club Panel Discussions (2012-5-5): Consequences of Fukushima Daiichi with Paul Gunter and Waste Disposal with Mary Olson, Physicians for Social Responsibility Seattle (2012-3-17),
Fukushima Daiichi Forum with Chiho Kaneko, Brattleboro, VT (2012-3-11),
Physicians for Global Responsibility Vancouver (2012-3-11) Skype Video Lecture, University of Vermont (2 - 2011),
Boston Nuclear Forum, Boston Library (6/16/11),
Duxbury Emergency Management (6/15/11),
Vermont State Nuclear Advisory Panel (VSNAP),
New Jersey Environmental Federation (5/14/11),
Press Conference for Physicians for Social Responsibility (5/19/11),
St. Johnsbury Academy - Nuclear Power 101.
More than 200 Educational videos on nuclear safety, reliability and engineering particularly Fukushima issues. Videos may be viewed @ fairewinds.org (501c3 non-profit)
Expert commentary (hundreds of TV, radio, print media, and internet interviews): CNN (8), The John King Show (16), BBC, CBC, Russia Today, Democracy Now, Al Jazeera America, KPBS (Radio & TV) VPR, WPTZ, WCAX, WBAI, CCTV, NECN, Pacifica Radio, CBC (radio & TV) (4), Rachel Maddow Show, Washington Post, New York Times, Tampa Bay Times, The Guardian, Bloomberg (print & TV), Reuters, Associated Press, The Global Post, Miami Herald, Orange County Times, LA Times, Al Jazeera (print), The Tennessean, The Chris Martinson Show, Mainichi News, TBS Japan, Gendai Magazine, NHK television, Scientific American. Huffington Post (Paris) named Fairewinds.com the best go to site for information about the Fukushima Daiichi accident (5/9/11).
Special Remediation Expertise:
Director of Engineering, Vice President of Site Engineering, and the Senior Vice President of Engineering at Nuclear Energy Services (NES) Division of Penn Central Corporation (PCC)
! NES was a nuclear licensee that specialized in dismantlement and remediation of nuclear facilities and nuclear sites. Member of the radiation safety committee for this licensee.
! Department of Energy chose NES to write DOE Decommissioning Handbook because NES had a unique breadth and depth of nuclear engineers and nuclear physicists on staff.
! Personally, I wrote the Small Bore Piping chapter of the DOEs first edition Decommissioning Handbook, personnel on my staff authored other sections, and I reviewed the entire Decommissioning Handbook.
! Served on the Connecticut Low Level Radioactive Waste Advisory Committee for 10 years from its inception.
! Managed groups performing analyses on dozens of dismantlement sites to thoroughly remove radioactive material from nuclear plants and their surrounding environment.
! Managed groups assisting in decommissioning the Shippingport nuclear power reactor.
Shippingport was the first large nuclear power plant ever decommissioned. The decommissioning of Shippingport included remediation of the site after decommissioning.
Page 17 of 20
! Managed groups conducting site characterizations (preliminary radiation surveys prior to commencement of removal of radiation) at the radioactively contaminated West Valley site in upstate New York.
! Personnel reporting to me assessed dismantlement of the Princeton Avenue Plutonium Lab in New Brunswick, NJ. The labs dismantlement assessment was stopped when we uncovered extremely toxic and carcinogenic underground radioactive contamination.
! Personnel reporting to me worked on decontaminating radioactive thorium at the Cleveland Avenue nuclear licensee in Ohio. The thorium had been used as an alloy in turbine blades.
During that project, previously undetected extremely toxic and carcinogenic radioactive contamination was discovered below ground after an aboveground gamma survey had purported that no residual radiation remained on site.
Additional Expert Qualifications - including and not limited to:
o Nuclear engineering management assessment, prudency assessment, contract administration, assessment and review o
Nuclear power plant licensing and permitting - assessment and review o
Decommissioning experience: including radioactive waste processes, storage issue assessment, and waste disposal o
Nuclear safety and risk assessment, source term reconstruction, dose assessments, criticality analysis, and thermohydraulic assessment (i.e. power plant steam generation) o Systems engineering and structural engineering assessments o
Cooling tower operation, cooling tower plumes, thermal discharge assessment, and consumptive water use o
Technical patents, nuclear fuel rack design and manufacturing, and nuclear equipment design and manufacturing o
Reliability engineering, & aging plant management assessments, in-service inspection o
Employee awareness programs, whistleblower protection, and public communications o
Quality Assurance (QA) & records Nuclear Engineering Experience 1970 to Present Expert witness testimony in nuclear litigation and administrative hearings in federal, international, and state court and to Nuclear Regulatory Commission, including but not limited to: Three Mile Island, US Federal Court, US NRC, NRC ASLB, ACRS, and Petition Review Board, California Public Utilities Commission, Canadian Nuclear Safety Commission (CNSC), Diet (Parliament)
Japan, House of Commons (UK), Vermont State Legislature, Vermont State Public Service Board, Vermont Public Utility Commission, Florida Public Service Board, Czech Senate, Connecticut State Legislature, Western Atlas Nuclear Litigation, U.S. Senate Nuclear Safety Hearings, Peach Bottom Nuclear Power Plant Litigation, and Office of the Inspector General NRC, and numerous Congressional Briefings and Hearings.
Nuclear Engineering, Safety, and Reliability Expert Witness 1990 to Present
! Fairewinds Associates, Inc - Chief Engineer, 2005 to Present
! Arnold Gundersen, Nuclear Safety Consultant and Energy Advisor, 1995 to 2005
! GMA - 1990 to 1995, including expert witness testimony regarding the accident at Three Mile Island.
Page 18 of 20 Nuclear Energy Services, Division of PCC (Fortune 500 company) 1979 to 1990 Corporate Officer and Senior Vice President - Technical Services - Responsible for overall performance of the company's Inservice Inspection (ASME XI), Quality Assurance (SNTC 1A),
and Staff Augmentation Business Units - up to 300 employees at various nuclear sites.
Senior Vice President of Engineering - Responsible for the overall performance of the company's Site Engineering, Boston Design Engineering and Engineered Products Business Units.
Integrated the Danbury based, Boston based and site engineering functions to provide products such as fuel racks, nozzle dams, and transfer mechanisms and services such as materials management and procedure development.
Vice President of Engineering Services - Responsible for the overall performance of the company's field engineering, operations engineering, and engineered products services.
Integrated the Danbury-based and field-based engineering functions to provide numerous products and services required by nuclear utilities, including patents for engineered products.
General Manager of Field Engineering - Managed and directed NES' multi-disciplined field engineering staff on location at various nuclear plant sites. Site activities included structural analysis, procedure development, technical specifications and training. Have personally applied for and received one patent.
Director of General Engineering - Managed and directed the Danbury based engineering staff.
Staff disciplines included structural, nuclear, mechanical and systems engineering. Responsible for assignment of personnel as well as scheduling, cost performance, and technical assessment by staff on assigned projects. This staff provided major engineering support to the company's nuclear waste management, spent fuel storage racks, and engineering consulting programs.
New York State Electric and Gas Corporation (NYSE&G) 1976 to 1979 Reliability Engineering Supervisor - Organized and supervised reliability engineers to upgrade performance levels on seven operating coal units and one that was under construction. Applied analytical techniques and good engineering judgments to improve capacity factors by reducing mean time to repair and by increasing mean time between failures.
Lead Power Systems Engineer - Supervised the preparation of proposals, bid evaluation, negotiation and administration of contracts for two 1300 MW NSSS Units including nuclear fuel, and solid-state control rooms. Represented corporation at numerous public forums including TV and radio on sensitive utility issues. Responsible for all nuclear and BOP portions of a PSAR, Environmental Report, and Early Site Review.
Northeast Utilities Service Corporation (NU) 1972 to 1976 Engineer - Nuclear Engineer assigned to Millstone Unit 2 during start-up phase. Lead the high velocity flush and chemical cleaning of condensate and feedwater systems and obtained discharge permit for chemicals. Developed Quality Assurance Category 1 Material, Equipment and Parts List. Modified fuel pool cooling system at Connecticut Yankee, steam generator blowdown system and diesel generator lube oil system for Millstone. Evaluated Technical Specification Change Requests.
Associate Engineer - Nuclear Engineer assigned to Montague Units 1 & 2. Interface Engineer with NSSS vendor, performed containment leak rate analysis, assisted in preparation of PSAR
Page 19 of 20 and performed radiological health analysis of plant. Performed environmental radiation survey of Connecticut Yankee. Performed chloride intrusion transient analysis for Millstone Unit 1 feedwater system. Prepared Millstone Unit 1 off-gas modification licensing document and Environmental Report Amendments 1 & 2.
Rensselaer Polytechnic Institute (RPI) 1971 to 1972 Critical Facility Reactor Operator, Instructor - Licensed AEC Reactor Operator instructing students and utility reactor operator trainees in start-up through full power operation of a reactor.
Public Service Electric and Gas (PSE&G) 1970 Assistant Engineer - Performed shielding design of radwaste and auxiliary buildings for Newbold Island Units 1 & 2, including development of computer codes.
Additional Publications (continued from front page)
Co-author -- Fairewinds Associates 2009-2010 Summary to JFC, July 26, 2010 State of Vermont, Joint Fiscal Office, (http://www.leg.state.vt.us/jfo/envy.aspx).
Co-author -- Supplemental Report of the Public Oversight Panel Regarding the Comprehensive Reliability Assessment of the Vermont Yankee Nuclear Power Plant July 20, 2010, to the Vermont State Legislature by the Vermont Yankee Public Oversight Panel.
Co-author The Second Quarterly Report by Fairewinds Associates, Inc to the Joint Legislative Committee regarding buried pipe and tank issues at Entergy Nuclear Vermont Yankee and Entergy proposed Enexus spinoff. See two reports: Fairewinds Associates 2nd Quarterly Report to JFC and Enexus Review by Fairewinds Associates.
Co-author Fairewinds Associates, Inc First Quarterly Report to the Joint Legislative Committee, October 19, 2009.
Co-author Report of the Public Oversight Panel Regarding the Comprehensive Reliability Assessment of the Vermont Yankee Nuclear Power Plant, March 17, 2009, to the Vermont State Legislature by the Vermont Yankee Public Oversight Panel.
Co-author Vermont Yankee Comprehensive Vertical Audit - VYCVA - Recommended Methodology to Thoroughly Assess Reliability and Safety Issues at Entergy Nuclear Vermont Yankee, January 30, 2008 Testimony to Finance Committee Vermont Senate.
Co-author Decommissioning Vermont Yankee - Stage 2 Analysis of the Vermont Yankee Decommissioning Fund - The Decommissioning Fund Gap, December 2007, Fairewinds Associates, Inc. Presented to Vermont State Senators and Legislators.
Co-author Decommissioning the Vermont Yankee Nuclear Power Plant: An Analysis of Vermont Yankees Decommissioning Fund and Its Projected Decommissioning Costs, November 2007, Fairewinds Associates, Inc.
Media Organizations - including and not limited to:
Featured Nuclear Safety and Reliability Expert (1990 to present) for Television, Newspaper, Radio,
& Internet - Including, and not limited to: CNN: JohnKingUSA, CNN News, Earth Matters; DemocracyNow, NECN, WPTZ VT, WTNH, VPTV, WCAX, RT, CTV (Canada), CCTV Burlington, VT, CAN TV (Chicago Access), ABC, TBS/Japan, Bloomberg: EnergyNow, KPBS, Japan National Press Club (Tokyo), Italy National Press Club (Rome), The Crusaders, Front Page, Five OClock Shadow: Robert Knight, Mark Johnson Show, Steve West Show, Anthony Polina Show, WKVT, WDEV, WVPR, WZBG CT, Seven Days, AP News Service, Houston Chronicle, Christian Science Monitor, Reuters, The Global Post, International Herald, The Guardian, New York
Page 20 of 20 Times, Washington Post, LA Times, Miami Herald, St. Petersburg Times, Brattleboro Reformer, Rutland Herald, Times-Argus, Burlington Free Press, Litchfield County Times, The News Times, The New Milford Times, Hartford Current, New London Day, Vermont Daily Briefing, Green Mountain Daily, EcoReview, Huffington Post, DailyKos, Voice of Orange County, AlterNet, Common Dreams, Gendai Media, Truthout, Progressive Radio Network, Project Censored and numerous other national and international blogs Public Service, Cultural, and Community Activities 2008 to Present -Fairewinds Energy Education Corp 501(C)3 non-profit board member 2005 to Present - Public presentations and panel discussions on nuclear power safety, reliability, economics, waste disposal, and decommissioning at numerous universities and colleges in the US, Canada, and Japan - including: DePaul University, Plymouth State University, Northwestern University, Life Chiropractic West, Middlebury College, McGill University, Hofstra University, New York School of Medicine, Cal Poly, Sonoma State, Amherst College, University of Vermont, Vermont Law School, Tokyo University, and before the Nuclear Regulatory Commission in hearings, Federal Court, Town and City Select Boards, Legal Panels, Local Schools, and via National & International Media: Television, Radio, Print, & Internet.
2007-2008 - Energy Production - created concept of Solar Panels on Burlington High School; worked with Burlington Electric Department and Burlington Board of Education Technology Committee on Grant for installation of solar collectors for Burlington Electric peak summer use; Grant was developed with assistance from Senator Sanders.
Vermont State Legislature - Public Testimony to Legislative Committees regarding nuclear power and energy issues NNSN - National Nuclear Safety Network, Founding Advisory Board Member, meetings with and testimony to the Nuclear Regulatory Commission Inspector General (NRC IG)
New York State Electric & Gas (NYSE&G) Speakers Club speaking about nuclear waste issues.
Northeast Utilities Representative Conducting Public Lectures on Nuclear Safety Issues with the Northeast Utilities Speakers Bureau End
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1 ATTACHMENT MNC-1 CURRICULUM VITA OF MARK COOPER MARK N. COOPER 504 HIGHGATE TERRACE SILVER SPRING, MD 20904 (301) 384-2204 markcooper@aol.com EDUCATION:
Yale University, Ph.D., 1979, Sociology University of Maryland, M.A., 1973, Sociology City College of New York, B.A., 1968, English PROFESSIONAL EXPERIENCE:
President, Citizens Research, 1983 - present Research Director, Consumer Federation of America, 1983-present Senior Fellow for Economic Analysis, Institute for Energy and the Environment, Vermont Law School 2009-present Associated Fellow, Columbia Institute on Tele-Information, 2003-2016 Fellow, Donald McGannon Communications Research Center, Fordham University, 2005-2015 Fellow, Silicon Flatirons, University of Colorado, 2009-2014 Fellow, Stanford Center on Internet and Society, 2000-2010 Principle Investigator, Consumer Energy Council of America, Electricity Forum, 1985-1994 Director of Energy, Consumer Federation of America, 1984-1986 Director of Research, Consumer Energy Council of America, 1980-1983 Consultant, Office of Policy Planning and Evaluation, Food and Nutrition Service, United States Department of Agriculture, 1981-1984 Consultant, Advanced Technology, Inc., 1981 Technical Manager, Economic Analysis and Social Experimentation Division, Applied Management Sciences, 1979 Research Associate, American Research Center in Egypt, 1976-1977 Research Fellow, American University in Cairo, 1976 Staff Associate, Checchi and Company, Washington, D.C., 1974-1976 Consultant, Division of Architectural Research, National Bureau of Standards, 1974 Consultant, Voice of America, 1974 Research Assistant, University of Maryland, 1972-1974 TEACHING EXPERIENCE:
Lecturer, Washington College of Law, American University, Spring, 1984 - 1986, Seminar in Public Utility Regulation Guest Lecturer, University of Maryland, 1981-82, Energy and the Consumer, American University, 1982, Energy Policy Analysis Assistant Professor, Northeastern University, Department of Sociology, 1978-1979, Sociology of Business and Industry, Political Economy of Underdevelopment, Introductory Sociology, Contemporary Sociological Theory; College of Business Administration, 1979, Business and Society Assistant Instructor, Yale University, Department of Sociology, 1977, Class, Status and Power Teaching Assistant, Yale University, Department of Sociology, 1975-1976, Methods of Sociological Research, The Individual and Society Instructor, University of Maryland, Department of Sociology, 1974, Social Change and Modernization, Ethnic Minorities Instructor, U.S. Army Interrogator/Linguist Training School, Fort Hood, Texas, 1970-1971 PROFESSIONAL ACTIVITIES:
Member, Advisory Committee on Appliance Efficiency Standards, U.S. Department of Energy, 1996 - 1998 Member, Energy Conservation Advisory Panel, Office of Technology Assessment, 1990-1991 Fellow, Council on Economic Regulation, 1989-1990 Member, Increased Competition in the Electric Power Industry Advisory Panel, Office of Technology Assessment, 1989 Participant, National Regulatory Conference, The Duty to Serve in a Changing Regulatory Environment, William and Mary, May 26, 1988 Member, Subcommittee on Finance, Tennessee Valley Authority Advisory Panel of the Southern States Energy Board, 1986-1987 Member, Electric Utility Generation Technology Advisory Panel, Office of Technology Assessment, 1984 - 1985
2 Member, Natural Gas Availability Advisor Panel, Office of Technology Assessment, 1983-1984 Participant, Workshop on Energy and the Consumer, University of Virginia, November 1983 Participant, Workshop on Unconventional Natural Gas, Office of Technology Assessment, July 1983 Participant, Seminar on Alaskan Oil Exports, Congressional Research Service, June 1983 Member, Thermal Insulation Subcommittee, National Institute of Building Sciences, 1981-1982 Round Table Discussion Leader, The Energy Situation: An Open Field For Sociological Analysis, 51st Annual Meeting of the Eastern Sociological Society, New York, March, 1981 Member, Building Energy Performance Standards Project Committee, Implementation Regulations Subcommittee, National Institute of Building Sciences, 1980-1981 Participant, Summer Study on Energy Efficient Buildings, American Council for an Energy Efficient Economy, August 1980 Member, University Committee on International Student Policy, Northeastern University, 1978-1979 Chairman, Session on Dissent and Societal Reaction, 45th Annual Meeting of the Eastern Sociological Society, April, 1975 Member, Papers Committee, 45th Annual Meeting of the Eastern Sociological Society, 1975 Student Representative, Programs, Curricula and Courses Committee, Division of Behavioral and Social Sciences, University of Maryland, 1973-1974 President, Graduate Student Organization, Department of Sociology, University of Maryland, 1973-1974 HONORS AND AWARDS:
Ester Peterson Award for Consumer Service, 2010 American Sociological Association, Travel Grant, Uppsala, Sweden, 1978 Fulbright-Hayes Doctoral Research Abroad Fellowship, Egypt, 1976-1977 Council on West European Studies Fellowship, University of Grenoble, France, 1975 Yale University Fellowship, 1974-1978 Alpha Kappa Delta, Sociological Honorary Society, 1973 Phi Delta Kappa, International Honorary Society, 1973 Graduate Student Paper Award, District of Columbia Sociological Society, 1973 Science Fiction Short Story Award, University of Maryland, 1973 Maxwell D. Taylor Award for Academic Excellence, Arabic, United States Defense Language Institute, 1971 Theodore Goodman Memorial Award for Creative Writing, City College of New York, 1968 New York State Regents Scholarship, 1963-1968 National Merit Scholarship, Honorable Mention, 1963 PUBLICATIONS:
ENERGY Books and Chapters The Political Economy of Electricity: Progressive Capitalism and the Struggle to Build a Sustainable Power Sector (Praeger, 2017)
Energy Justice in Theory and Practice: Building a Pragmatic, Progressive Road Map, in Thijs de Graf, Benjamin K. Sovacool, Arunabha Gosh, Florian Kern, and Michael T. Klare (Eds.) The Palgrave Handbook of the International Political Economy of Energy, (PALGRAVE, Macmillan, 2016)
Recognizing the Limits of Markets, Rediscovering Public Interest in Utilities, in Robert E. Willett (ed), Electric and Natural Gas Business:
Understanding It! (2003 and Beyond) (Houston: Financial Communications: 2003)
"Protecting the Public Interest in the Transition to Competition in Network Industries," The Electric Utility Industry in Transition (Public Utilities Reports, Inc. & the New York State Energy Research and Development Authority, 1994)
"The Seven Percent Solution: Energy Prices, Energy Policy and the Economic Collapse of the 1970s," in Energy Concerns and American Families in the 1980s (Washington, D.C.: The American Association of University Women Educational Foundation, 1983)
"Natural Gas Policy Analysis," in Edward Mitchell (Ed.), Natural Gas Pricing Policy (Washington, D.C.: American Enterprise Institute, 1983)
Equity and Energy: Rising Energy Prices and the Living Standard of Lower Income Americans (Boulder, Colorado: Westview Press, 1983)
Articles and Papers:
Governing the Global Climate Commons: The Political Economy of State and Local Action, After the U.S. Flip-Flop on the Paris Agreement, Energy Policy, 2018.
Renewable and distributed resources in a post-Paris low carbon future: The key role and political economy of sustainable electricity, Energy Research & Social Science, 19 (2016) 66-93.
The Unavoidable Economics of Nuclear Power. Corporate Knights, January 22, 2014.
Energy Efficiency Performance Standards: Driving Consumer and Energy Savings in California.Presentation at the California Energy Commission's Energy Academy, February 20, 2014.
Small modular reactors and the future of nuclear power in the United States, Energy Research & Social Science, 2014.
The EPA carbon plan: Coal loses, but nuclear doesn't win, Bulletin of the Atomic Scientists, 70, 2014
3 Multi-Criteria Portfolio Analysis of Electricity Resources: An Empirical Framework For Valuing Resource In An Increasingly Complex Decision-Making Environment, Expert Workshop: System Approach to Assessing the Value of Wind Energy to Society, European Commission Joint Research Centre, Institute for Energy and Transport, Petten, The Netherlands, November 13-14, 2013 Nuclear aging: Not so gracefully, Bulletin of the Atomic Scientists, 69, 2013 Nuclear Safety and Affordable Reactors: Can We Have Both?, Bulletin of the Atomic Scientists, 68, 2012 Nuclear Safety and Nuclear Economics, Fukushima Reignites the Never-ending Debate: Is Nuclear Power not worth the risk at any price?,
Symposium on the Future of Nuclear Power, University of Pittsburgh, March 27-28, 2012 Nuclear liability: the post-Fukushima case for ending Price-Anderson, Bulletin of the Atomic Scientists, October, 67, 2011.
Prudent Resource Acquisition in a Complex Decision-Making Environment: Multidimensional Analysis Highlights the Superiority of Efficiency, Current Approaches to Integrated Resource Planning, 2011 ACEEE National Conference on Energy Efficiency as a Resource, Denver, September 26, 2011 The Implications of Fukushima: The US perspective, Bulletin of the Atomic Scientists, July/August 2011 67: 8-13 Least Cost Planning for 21st Century Electricity Supply: Meeting the Challenges of Complexity and Ambiguity in Decision Making, MACRUC Annual Conference, June 5, 2011 Risk, Uncertainty and Ignorance: Analytic Tools for Least-Cost Strategies to Meet Electricity Needs in a Complex Age, Variable Renewable Energy and Natural Gas: Two Great Things that Go Together, or Best Not to Mix Them. NARUC Winter Committee Meetings, Energy Resources, Environment and Gas Committee, February 15, 2011 The Failure of Federal Authorities to Protect American Energy Consumers From Market Power and Other Abusive Practices, Loyola Consumer Law Review, 19:4 (2007)
Too Much Deregulation or Not Enough, Natural Gas and Electricity, June 2005 Real Energy Crisis is $200 Billion Natural Gas Price Increase, Natural Gas and Electricity, August 2004 Regulators Should Regain Control to Prevent Abuses During Scarcity, Natural Gas, August 2003 Economics of Power: Heading for the Exits, Deregulated Electricity Markets Not Working Well, Natural Gas, 19:5, December 2002 Lets Go Back, Public Power, November-December 2002 "Conceptualizing and Measuring the Burden of High Energy Prices," in Hans Landsberg (Ed.), High Energy Costs: Assessing the Burden (Washington, D.C.: Resources For the Future, 1982)
"Energy Efficiency Investments in Single Family Residences: A Conceptualization of Market Inhibitors," in Jeffrey Harris and Jack Hollander (Eds.), Improving Energy Efficiency in Buildings: Progress and Problems (American Council for An Energy Efficient Economy, 1982)
"Policy Packaging for Energy Conservation: Creating and Assessing Policy Packages," in Jeffrey Harris and Jack Hollander (Eds.), Improving Energy Efficiency in Buildings: Progress and Problems (American Council for An Energy Efficient Economy, 1982)
"The Role of Consumer Assurance in the Adoption of Solar Technologies," International Conference on Consumer Behavior and Energy Policy, August, 1982 "Energy and the Poor," Third International Forum on the Human Side of Energy, August, 1982 "Energy Price Policy and the Elderly," Annual Conference, National Council on the Aging, April, 1982 "Energy and Jobs: The Conservation Path to Fuller Employment," Conference on Energy and Jobs conducted by the Industrial Union Department of the AFL-CIO, May 1980 Research Reports Avoiding Nuclear and Fossil Fuel Potholes, A Green New Deal Has a Clear Path to a Clean, Low Cost, Low Carbon, Progressive, Capitalist Electricity Sector, Institute for Energy and the Environment, April 2019 A Clean Slate for Vogtle, Clean Energy for Georgia: The Case for Ending Construction at the Vogtle Nuclear Power Plant and Reorienting Policy to Least-Cost, Clean Alternatives, for the Sierra Club of Georgia, February 2018 The Failure of The Nuclear Gamble In South Carolina: Regulators can Save Consumers Billions by Pulling the Plug on Summer 2 & 3 Already Years behind Schedule and Billions Over Budget Things are Likely to Get Much Worse if the Project Continues, for the Sierra Club of South Carolina, July 2017 Power Shift, The Nuclear War Against the Future: How Nuclear Advocates Are Thwarting the Deployment of a 21st Century Electricity Sector.
Institute for Energy and the Environment, Vermont Law School, May, 2015.
Advanced Cost Recovery;Institute for Energy and the Environment, Vermont Law School, September 2013 Renaissance In Reverse: Competition Pushes Aging U.S. Nuclear Reactors To The Brink Of Economic Abandonment, Institute For Energy And The Environment, Vermont Law School, July 2013.
Energy Efficiency Performance Standards: The Cornerstone of Consumer-Friendly Energy Policy, October 2013 The Zero Emissions Vehicle Program: Clean Cars States Lead in Innovation,October 24, 2013 Renaissance in Reverse: Competition Pushes Aging U.S. Nuclear Reactors to the Brink of Economic Abandonment, July 2013.
The Economic Feasibility, Impact On Public Welfare And Financial Prospects For New Nuclear Construction, For Utah Heal, July 2013 Public Risk, Private Profit, Ratepayer Cost, Utility Imprudence: Advanced Cost Recovery for Reactor Construction Creates another Nuclear Fiasco, Not a Renaissance, March 2013 Fundamental Flaws In SCE&Gs Comparative Economic Analysis, October 1, 2012 Capturing The Value Of Offshore Wind. Mainstream Renewable Power, October 2012.
4 Policy Challenges of Nuclear Reactor Construction: Cost Escalation and Crowding Out Alternatives,Institute for Energy and the Environment, Vermont Law School, September, 2010 U.S. Oil Market Fundamentals and Public Opinion, Consumer Federation of America, May 2010 Building on the Success of Energy Efficiency Programs to Ensure an Affordable Energy Future, Consumer Federation of America, February 2010 The Impact of Maximizing Energy Efficiency on Residential Electricity and Natural Gas Utility Bills in a Carbon-Constrained Environment:
Estimates of National and State-By-State Consumer Savings,Consumer Federation of America November 2009 Shifting Fuel Economy Standards into High Gear, Consumer Federation of America, November 24, 2009 A Consumer Analysis of Energy Efficiency and Renewable Energy Standards: The Cornerstone of Consumer-Friendly Energy/Environmental Policy, Consumer Federation of America, May 2009 All Risk; No Reward, Institute for Energy and the Environment, Vermont Law School, Dec 2009.
The Economics of Nuclear Reactors: Renaissance of Relapse, Institute for Energy and the Environment, Vermont Law School, June 2009.
A Consumer Analysis of the Adoption of the California Clean Cars Program in Other States: Florida, Consumer Federation of America, November 2008 A Boom for Big Oil - A Bust for Consumers: Ana analysis of Policies to Meet American Energy Needs, Consumer Federation of America, September 2008 Climate Change and the Electricity Consumer: Background Analysis to Support a Policy Dialogue, Consumer Federation of America, June 2008 Ending Americas Oil Addiction: A Quarterly Report on Consumption, Prices and Imports, Consumer Federation of America, April 2008 A Consumer Analysis of the Adoption of the California Clean Cars Program in Other States: Arizona, Consumer Federation of America, March 2008 A Step Toward A Brighter Energy Future, Consumer Federation of America, December 2007 A Consumer Analysis of the Adoption of the California Clean Cars Program in Other States: New Mexico, Consumer Federation of America, November 2007 Not Time to Waste: Americas Energy Situation Is Dangerous, But Congress Can Adopt New Policies to Secure Our Future, Consumer Federation of America, October 2007 Technology, Cost and Timing, Consumer Federation of America, July 2007 Floridas Stake in the Fuel Economy Battle, July 2007 Big Oil v. Ethanol, Consumer Federation of America, July 2007 Too Little, Too Late: Why the Auto Industry Proposal To Go Low and Slow on Fuel Economy Improvements Is Not in the Consumer or National Interest, Consumer Federation of America, July 2007 The Senate Commerce Committee Bill Is Much Better For Consumers and The Nation Than the Automobile Industry Proposal, Consumer Federation of America, June 2007 Rural Households Benefit More From Increases In Fuel Economy, Consumer Federation of America, June 207 A Consumer Pocketbook And National Cost-Benefit Analysis of 10 in10, Consumer Federation of America, June 2007 Time to Change the Record on Oil Policy, Consumer Federation of America, August 2006 50 by 2030: Why $3.00 Gasoline Makes the 50-Miles Per Gallon Car Feasible, Affordable and Economic, Consumer Federation of America, (May 2006)
The Role of Supply, Demand, Industry Behavior and Financial Markets in the Gasoline Price Spiral (Prepared for Wisconsin Attorney General Peggy A. Lautenslager, May 2006)
Debunking Oil Industry Myths and Deception: The $100 Billion Consumer Rip-Off (Consumer Federation of America and Consumers Union, May 3, 2006)
The Role of Supply, Demand and Financial Markets in the Natural Gas Price Spiral (prepared for the Midwest Attorneys General Natural Gas Working Group: Illinois, Iowa, Missouri, Wisconsin, March 2006)
The Impact of Rising Prices on Household Gasoline Expenditures (Consumer Federation of America, September 2005)
Responding to Turmoil in Natural Gas Markets: The Consumer Case for Aggressive Policies to Balance Supply and Demand (consumer Federation of America, December 2004)
Record Prices, Record Oil Company Profits: The Failure Of Antitrust Enforcement To Protect American Energy Consumers (Consumer Federation of America, Consumers Union, September 2004)
Fueling Profits: Industry Consolidation, Excess Profits, & Federal Neglect: Domestic Causes of Recent Gasoline and Natural Gas Price Shocks (Consumer Federation of America and Consumers Union, May 2004)
Spring Break in the U.S. Oil Industry: Price Spikes, Excess Profits and Excuses (Consumer Federation of America, October 2003)
How Electricity Deregulation Puts Pressure On The Transmission Network And Increases Its Cost (Consumer Federation of America, Consumers Union and U.S. PIRG, August 2003)
A Discouraging Word (or Two, or Three, or Four) About Electricity Restructuring in Texas, Pennsylvania, New England and Elsewhere Consumer Federation of America, U.S. Public Interest Research Group and Consumers Union, March 2003)
All Pain, No Gain: Restructuring and Deregulation in the Interstate Electricity Market (Consumer Federation of America, September 2002)
U.S. Capitalism and the Public Interest: Restoring the Balance in Electricity and Telecommunications Markets (Consumer Federation of America, August 2002)
5 Electricity Deregulation and Consumers: Lesson from a Hot Spring and a Cool Summer (Consumer Federation of America, August 30, 2001)
Ending the Gasoline Price Spiral: Market Fundamentals for Consumer-Friendly Policies to Stop the Wild Ride (Consumer Federation of America, July 2001)
Analysis of Economic Justifications and Implications of Taxing Windfall Profits in the California Wholesale Electricity Market (Consumer Federation of America and Consumers Union, June 13, 2001)
Behind The Headlines Of Electricity Restructuring A Story Of Greed, Irresponsibility And Mismanagement Of A Vital Service In A Vulnerable Market (Consumer Federation of America, March 20, 2001)
Reconsidering Electricity Restructuring: Do Market Problems Indicate a Short Circuit or a Total Blackout? (Consumer Federation of America, November 30. 2000)
Mergers and Open Access to Transmission in the Restructuring Electric Industry (Consumer Federation of America, April 2000)
Electricity Restructuring and the Price Spikes of 1998 (Consumer Federation of America and Consumers Union, June 1999)
The Residential Ratepayer Economics of Electric Utility Restructuring (Consumer Federation of America, July 1998)
Consumer Issues in Electric Utility Restructuring (Consumer Federation of America, February 12, 1998)
A Consumer Issue Paper on Electric Utility Restructuring (American Association of Retired Persons and the Consumer Federation of America, January, 1997)
Transportation, Energy, and the Environment: Balancing Goals and Identifying Policies, August 1995 A Residential Consumer View of Bypass of Natural Gas Local Distribution Companies, February 1988 The National Energy Security Policy Debate After the Collapse of Cartel Pricing: A Consumer Perspective, January 1987 The Energy, Economic and Tax Effects of Oil Import Fees, October 25, 1985 The Bigger the Better: The Public Interest in Building a Larger Strategic Petroleum Reserve, June 12, 1984 The Consumer Economics of CWIP: A Short Circuit for American Pocketbooks, April, 1984 Public Preference in Hydro Power Relicensing: The Consumer Interest in Competition, April 1984 Concept Paper for a Non-profit, Community-based, Energy Services Company, November 1983 The Consumer and Energy Impacts of Oil Exports, April 1983 Up Against the Consumption Wall: The Impact of Rising Energy Prices on Lower Income Consumers, March 1983 A Decade of Despair: Rising Energy Prices and the Living Standards of Lower Income Americans, September 1982 The Impact of Rising Energy Prices on the Delivery of Public Service by Local Governments, August 1982 The Impact of Rising Energy Prices on the Low-Income Population of the Nation, the South, and the Gulf Coast Region, July, 1982 A Comprehensive Analysis of the Impact of a Crude Oil Import Fee: Dismantling a Trojan Horse, April 1982 The Past as Prologue II: The Macroeconomic Impacts of Rising Energy prices, A Comparison of Crude Oil Decontrol and Natural Gas Deregulation, March, 1982 The Past as Prologue I: The Underestimation of Price Increases in the Decontrol Debate, A Comparison of Oil and Natural Gas, February 1982 Oil Price Decontrol and the Poor: A Social Policy Failure, February 1982 Natural Gas Decontrol: A Case of Trickle-Up Economics, January 1982 A Comprehensive Analysis of the Costs and Benefits of Low-Income Weatherization and Its Potential Relationship to Low Income Energy Assistance, June 1981 Summary of Market Inhibitors, February 1981 Program Models and Program Management Procedures for the Department of Energy's Solar Consumer Assurance Network Project: A Rapid Feedback Evaluation, February 1981 An Analysis of the Economics of Fuel Switching Versus Conservation for the Residential Heating Oil Consumer, October 1980 Energy Conservation in New Buildings: A Critique and Alternative Approach to the Department of Energy's Building Energy Performance Standards, April, 1980 The Basics of BEPS: A Descriptive Summary of the Major Elements of the Department of Energy's Building Energy Performance Standards, February, 1980 COMMUNICATIONS AND MEDIA Books and Chapters The Future of Journalism: Addressing Pervasive Market Failure with Public Policy, in R.W. McChesney and Victor Picard (eds.), Will the Last Reporter Turn out the Lights (New York: New Press, 2011)
Broadband in America: A Policy of Neglect is not Benign, in Enrico Ferro, Yogesh K. Dwivedi, J. Ramon Gil-Garcia, and Michael D.
Williams, Eds., Overcoming Digital Divides: Constructing an Equitable and Competitive Information Society, IGI Global Press, 2009.
Political Action and Internet Organization:An Internet-Based Engagement Model, in Todd Davies and Seeta Pena Gangaharian, Eds., Online Deliberation: Design, Research and Practice, CSLI press.
When Counting Counts: Marrying Advocacy and Academics in the Media Ownership Research Wars at the FCC, forthcoming in Lynn M.
Harter, Mohan J. Dutta, and Courtney Cole, Eds., Communicating for Social Impact: Engaging Communication Theory, Research, and Pedagogy, Hampton Press.
6 The Case Against Media Consolidation (Donald McGannon Communications Research Center, 2007)
Open Architecture as Communications Policy (Stanford Law School, Center for Internet and Society: 2004)
Media Ownership and Democracy in the Digital Information Age: Promoting Diversity with First Amendment Principles and Rigorous Market Structure Analysis (Stanford Law School, Center for Internet and Society: 2003)
Cable Mergers and Monopolies: Market Power In Digital Media and Communications Networks (Washington, D.C.: Economic Policy Institute, 2002)
When Law and Social Science Go Hand in Glove: Usage and Importance of Local and National News Sources, Critical Questions and Answers for Media Market Analysis,forthcoming in, Philip Napoli, Ed. Media Diversity and Localism: Meaning and Metrics, (Lawrence Erlbaum, 2007)
The Importance of Open Networks in Sustaining the Digital Revolution, in Thomas M. Lenard and Randolph J. May (Eds.) Net Neutrality or Net Neutering(New York, Springer, 2006)
Reclaiming The First Amendment: Legal, Factual And Analytic Support For Limits On Media Ownership, Robert McChesney and Benn Scott (Eds), The Future of Media (Seven Stories Press, 2005)
Building A Progressive Media And Communications Sector, Elliot Cohen (Ed.), News Incorporated: Corporate Media Ownership And Its Threat To Democracy (Prometheus Books, 2005)
Hyper-Commercialism In The Media: The Threat To Journalism And Democratic Discourse, Snyder-Gasher-Compton-(Eds), Converging Media, Diverging Politics: A Political Economy Of News In The United States And Canada(Lexington Books, 2005)
The Digital Divide Confronts the Telecommunications Act of 1996: Economic Reality versus Public Policy, in Benjamin M. Compaine (Ed.),
The Digital Divide: Facing a Crisis or Creating a Myth? (Cambridge: MIT Press, 2001)
Articles and Papers:
Business Data Services after the 1996 Act: Structure, Conduct, Performance in the Core of the Digital Communications Network The Failure of Potential Competition to Prevent Abuse of Market Power, Telecommunications Policy Research Conference, September, 2016.
with Gene Kimmelman, Antitrust and Economic Regulation: Essential and Complementary Tools to Maximize Consumer Welfare and Freedom of Expression in the Digital Age, Harvard Law & Policy Review 9-2 (2015)
The ICT Revolution in Historical Perspective: Progressive Capitalism as a Response to Free Market Fanaticism and Marxist Complaints in the Deployment Phase of the Digital Mode of Production. Telecommunication Policy Research Conference Session on Innovation, September 28, 2015.
The Long History and Increasing Importance of Public Service Principles For 21st Century Public Digital Communications Networks, Journal on Telecommunications and High Technology Law, 2014 From the Public Switched Telephone Network to the Public Digital Communications Network: Interconnection, Interoperability, Universal Service & Innovation at the Edge, Interconnection Policy for the Internet Age, The Digital Broadband Migration: The Future of Internet-Enabled Innovation, Silicon Flatirons, February 10-11, 2013 Why Growing Up is Hard to Do: Institutional Challenges for Internet Governance in the Quarter Life Crisis of the of the Digital Revolution, Journal on Telecommunications and High Technology Law, 2013. 11(1).
Structured Viral Communications: The Political Economy and Social Organization of Digital Disintermediation, Journal on High Telecommunications and High Technology Law, 9:1, 2011.
Crowd Sourcing Enforcement: Building a Platform for Participatory Regulation in the Digital Information Age, presentation at The Digital Broadband Migration: The Dynamics of Disruptive Innovation, Silicon Flatirons Ctr. Feb. 12, 2011 The Central Role of Wireless in the 21st Century Communications Ecology: Adapting Spectrum and Universal Service Policy to the New Reality, Telecommunications Policy Research Conference, September 2011 Round #1 in the Digital Intellectual Property Wars: Economic Fundamentals, Not Piracy, Explain How Consumers and Artists Won in the Music Sector, Telecommunications Policy Research Conference, September 2008.
When The Market Does Not Reign Supreme: Localism And Diversity In U.S. Media Policy, International Communications Association, forthcoming, May 2008 Minority Programming: Still at The Back of the Bus, International Communications Association, May 2008, with Adam Lynn Traditional Content Is Still King as the Source of Local News and Information, International Communications Association, forthcoming, May 2008 Junk Science And Administrative Abuse In The Effort Of The FCC To Eliminate Limits On Media Concentration, International Communications Association, May 2008.
Contentless Content Analysis: Flaws In The Methodology For Analyzing The Relationship Between Media Bias And Media Ownership, forthcoming, International Communications Association, May 2008.
Network Neutrality, Toll Roads? The Legal and Political Debate Over Network Neutrality, University of San Francisco Law School, January 26, 2008 with Derek Turner, 2007, The Negative Effect of Concentration and Vertical Integration on Diversity and Quality in Video Entertainment, Telecommunications Policy Research Conference, 2007 The Lack of Racial and Gender Diversity in Broadcast Ownership and The Effects of FCC Policy: An Empirical Analysis, Telecommunications Research Policy Conference, September 2007, with Derek Turner New Media and Localism: Are Local Cable Channels and Locally Focused Websites Significant New and Diverse Sources of Local News and Information? An Empirical Analysis, Telecommunications Research Policy Conference, September 2007, with Adam Lynn
7 A Case Study of Why Local Reporting Matters: Photojournalism Framing of the Response to Hurricane Katrina in Local and National Newspapers, International Communications Association, May 2007.
Will the FCC Let Local Media Rise from the Ashes of Conglomerate Failure, International Communications Association, May 2007.
The Failure of Federal Authorities to Protect American Energy Consumers From Market Power and Other Abusive Practices, Loyola Consumer Law Review, 19:4 (2007)
The Central Role of Network Neutrality in the Internet Revolution, Public Interest Advocacy Center, Ottawa Canada, November 24, 2006 Governing the Spectrum Commons, September 2006. Telecommunications Policy Research Conference, October 2006 Accessing the Knowledge Commons in the Digital Information Age, Consumer Policy Review, May/June 2006 Independent, Non-Commercial Video, Beyond Broadcast,Berkman Center, Harvard University, May 12, 2006 Defining Appropriation Right in the Knowledge Commons of the Digital Information Age: Rebalancing the Role of Private Incentives and Public Circulation in Granting Intellectual Monopoly Privileges, Legal Battle Over Fair Use, Copyright, and Intellectual Property, March 25, 2006 The Economics of Collaborative Production: A Framework for Analyzing the Emerging Mode of Digital Production, The Economics of Open Content: A Commercial Noncommercial Forum,MIT January 23, 2006 From Wifi to Wikis and Open Source: The Political Economy of Collaborative Production in the Digital Information Age, Journal on Telecommunications and High Technology Law, 5:1, 2006 Information is a Public Good, Extending the Information Society to All: Enabling Environments, Investment and Innovation, World Summit on the Information Society, Tunis, November 2005 The Importance of Collateral Communications and Deliberative Discourse in Building Internet-Based Media Reform Movements, Online Deliberation: Design, Research and Practice/DIAC, November, 2005 Collaborative Production in Group-Forming Networks: The 21st Century Mode of Information Production and the Telecommunications Policies Necessary to Promote It, The State of Telecom: Taking Stock and Looking Ahead, Columbia Institute on Tele-Information, October 2005 The Economics of Collaborative Production in the Spectrum Commons, IEEE Symposium on New Frontiers in Dynamic Spectrum Access Networks, November 2005 Independent Noncommercial Television: Technological, Economic and Social Bases of A New Model of Video Production, Telecommunications Policy Research Conference, October 2005 Spectrum as Speech in the 21st Century, The Public Airwaves as a Common Asset and a Public Good: Implications for the Future of Broadcasting and Community Development in the U.S., Ford foundation, March 11, 2005 When Law and Social Science Go Hand in Glove: Usage and Importance of Local and National News Sources, Critical Questions and Answers for Media Market Analysis,Telecommunications Policy Research Conference, October 2004 Dividing the Nation, Digitally: When a Policy Of Neglect is Not Benign, The Impact of the Digital Divide on Management and Policy:
Determinants and Implications of Unequal Access to Information Technology,Carlson School of Management, University of Minnesota, August 28, 2004.
Limits on Media Ownership are Essential, Television Quarterly,Spring Summer 2004 Applying the Structure, Conduct Performance Paradigm of Industrial Organization to the Forum for Democratic Discourse, Media Diversity and Localism, Meaning, Metrics and Public Interest, Donald McGannon Communications Research Center, Fordham University, December 2003 Cable Market Power, Pricing And Bundling After The Telecommunications Act Of 1996:
Explorations Of Anti-Consumer, Anticompetitive Practices, Cable TV Rates: Has Deregulation Failed?, Manhattan Institute, November 2003 Hope And Hype Vs. Reality: The Role Of The Commercial Internet In Democratic Discourse And Prospects For Institutional Change, Telecommunication Policy Research Conference, September 21, 2003 Ten Principles For Managing The Transition To Competition In Local Telecommunications Markets, Triennial Review Technical Workshop National Association of Regulatory Utility Commissioners, Denver CO, July 27, 2003 Universal Service: A Constantly Expanding Goal, Consumer Perspectives on Universal Service: Do Americans Lose Under a Connection-based Approach? (Washington, D.C.: New Millennium Research Council, June 2003)
The Evidence Is Overwhelming: Diversity, Localism And The Public Interest Are The Victims Of Concentration, Conglomeration And Consolidation Of The Commercial Mass Media Concentration And Local Markets, The Information Policy Institute and The Columbia Institute On Tele-Information The National Press Club, Washington, DC, March 11, 2003 Loss Of Diversity, Localism And Independent Voices Harms The Public Interest: Some Recent Examples, The Information Policy Institute and The Columbia Institute On Tele-Information The National Press Club, Washington, DC, March 11, 2003 Open Communications in Open Economies and Open Societies: Public Interest Obligations are Vital in the Digital Information Age, Convergence: Broadband Policy and Regulation Issues for New Media Businesses in the New Millennium Georgetown University Law Center, Advanced Computer and Internet Law Institute March 5, 2003.
The Political Economy Of Spectrum Policy: Unlicensed Use Wins Both The Political (Freedom Of Speech) And Economic (Efficiency)
Arguments, Spectrum Policy: Property Or Commons? Stanford Law School, March 1, 2003 Whats New About Telecommunications in the 21st Century Economy: Not Enough to Abandon Traditional 20th century Public Interest Values Models of Regulation For the New Economy, University of Colorado School of Law, February 1, 2003 Comments on Broadband: Bringing Home the Bits,Columbia Institute for Tele-Information, March 18, 2002
8 Fair Use and Innovation First, Litigation Later: Why digitally Retarding Media (DRM) Will slow the Transition to the Digital Information Age, Online Committee, Federal Communications Bar Association,January 29, 2003 Open Communications Platforms: Cornerstone of Innovation and Democratic Discourse In the Internet Age, Journal on Telecommunications, Technology and Intellectual Property, 2:1, 2003, Foundations And Principles Of Local Activism In The Global, New Economy, The Role of Localities and States in Telecommunications Regulation: Understanding the Jurisdictional Challenges in an Internet Era, University of Colorado Law School, `April 16, 2001 The Role Of Technology And Public Policy In Preserving An Open Broadband Internet, The Policy Implications Of End-To-End,Stanford Law School, December 1, 2000 Inequality In The Digital Society: Why The Digital Divide Deserves All The Attention It Gets, Cardozo Arts and Entertainment Law Journal,2002, first presented at Bridging The Digital Divide: Equality In The Information Age, Cardozo School Of Law, November 15, 2000 Picking Up The Public Policy Pieces Of Failed Business And Regulatory Models, Setting The Telecommunications Agenda, Columbia Institute For Tele-Information November 3, 2000 Progressive, Democratic Capitalism In The Digital Age, 21st Century Technology and 20th Century Law: Where Do We Go from Here? The Fund for Constitutional Government, Conference on Media, Democracy and the Constitution, September 27, 2000 Open Access To The Broadband Internet: Technical And Economic Discrimination In Closed, Proprietary Networks, University of Colorado Law Review, Vol. 69, Fall 2000 Antitrust As Consumer Protection In The New Economy: Lessons From The Microsoft Case, Hastings Law Journal, 52: 4, April 2001, first presented at Conference On Antitrust Law In The 21st Century Hasting Law School, February 10, 2000 Evolving Concepts of Universal Service, The Federalist Society, October 18, 1996 "Delivering the Information Age Now," Telecom Infrastructure: 1993, Telecommunications Reports, 1993 "Divestiture Plus Four: Take the Money and Run," Telematics, January 1988 "Regulatory Reform in Telecommunications: A Solution in Search of a Problem," Telematics, 4:11, November 1987.
"The Line of Business Restriction on the Regional Bell Operating Companies: A Plain Old Anti-trust Remedy for a Plain Old Monopoly,"
Executive Leadership Seminar on Critical Policy Developments in Federal Telecommunications Policy, The Brookings Institution, October 7, 1987 "The Downside of Deregulation: A Consumer Perspective After A Decade of Regulatory Reform," Plenary Session, Consumer Assembly, February 12, 1987 "Regulatory Reform for Electric Utilities, Plenary Session, Consumer Federation of American, Electric Utility Conference, April 4, 1987 "Round Two in the Post-Divestiture Era: A Platform for Consumer Political Action," Conference on Telephone Issues for the States -- 1984:
Implementing Divestiture, May, 1984 Research Reports Digital Disintermediation and Copyright in the 21st Century: Lessons From The Transformation Of The Music Sector, November 2013 E-Book Price Fixing Violates The Antitrust Laws And Harms Consumers, April 9, 2012 Efficiency Gains and Consumer Benefits of Unlicensed Access to the Public Airwaves: the Dramatic Success of Combining Market Principles and Shared Access,January 2012 The Impact of the Vertically Integrated, Television-Movie Studio Oligopoly on Source Diversity and Independent Production, Independent Film and Television Association, October 2006 How Bigger Media Will Hurt Alaska, Arkansas, California, Florida, Maine, Michigan, Montana, Ohio, Oregon, Pennsylvania, Tennessee, Texas, Virginia, Washington, Media and Democracy Coalition, October 2006 Mapping the Terrain in the Battle Over Access to Knowledge in the Digital Information Age (June 2006)
Online Deliberation: Mapping The Field; Tapping The Potential From The Perspective Of A Media/Internet Activist (August 2005)
Broken Promises and Strangled Competition: The Record of Baby Bell Merger and Market Opening Behavior (Consumer Federation of America, June 2005)
Over a Barrel: Why Arent Oil Companies Using Ethanol to Lower Gasoline Prices? (Consumer Federation of America, May 2005)
Reflections Of A Media Activist On New Strategies For Justice: Linking Corporate Law With Progressive Social Movements (May 2005)
Time for the Recording Industry to Face the Music: The Political, Social and Economic Benefits of Peer-to-Peer Communications Networks (Consumer Federation of America, Consumers Union, Free press, U.S. Public Interest Research Group, March 2005)
Expanding the Digital Divide and Falling Behind in Broadband (Consumer Federation of America and Consumers Union, October 2004)
Time to Give Consumers Real Cable Choices: After Two Decades of Anti-consumer Bundling and Anti-Competitive Gate keeping (Consumer Federation of America and Consumers Union, July 2004)
The Public Interest in Open Communications Networks (Consumer Federation of America, July 2004)
Caution Flag in the FCCs Race to Eliminate the Unbundled Network Element Platform (consumer Federation of America, June 2003)
New Survey Finds Americans Rely on Newspapers Much More than Other Media for Local News and Information: FCC Media Ownership Rules Based on Flawed Data(Consumer Federation of America, Consumers Unions, January 2004)
Cable Market Power, Pricing And Bundling After The Telecommunications Act Of 1996: Explorations Of Anti-Consumer, Anticompetitive Practices (Consumer Federation of America and Consumers Union, November 2003)
Competition At The Crossroads:Can Public Utility Commissions SaveLocal Phone Competition? (Consumer Federation of America, October 7, 2003)
9 Free TV Swallowed by Media Giants: The Way It Really Is, September 15, 2003 (Consumer Federation of America, Consumers Union and Center for Digital Democracy, September 15, 2003)
Abracadabra! Hocus-Pocus! Making Media Market Power Disappear With The FCCs Diversity Index (Consumer Federation of America and Consumers Union, July 2003)
Promoting The Public Interest Through Media Ownership Limits: A Critique Of The FCCs Draft Order Based On Rigorous Market Structure Analysis And High Competitive Standards (Consumer Federation of America and Consumers Union, May 2003)
Public Opinion Opposes The FCCs March Toward Concentrated Media Markets (Consumer Federation of America, April 2003)
Democratic Discourse in the Digital Information Age: Legal Principles and Economic Challenge (Consumer Federation of America, February 2003)
Cable Mergers, Monopoly Power and Price Increases (Consumer Federation of America and Consumers Union, January 2003)
Public Support for a Citizen-Friendly Media and Communications Industry in the Digital Age: A Review of Recent Survey Evidence (Consumer Federation of America, October 2002)
The Battle for Democratic Discourse: Recapturing a Bold Aspiration for the First amendment (Consumer Federation of America, October 2002)
Does the Digital Divide Still Exist? Bush Administration Shrugs, But Evidence Says Yes (Consumer Federation of America, Consumers Union, Civil Rights Forum, May 30, 2002)
The Failure of Intermodal Competition in Cable and Communications Markets (Consumer Federation of America and Consumers Union, April, 2002).
Competitive Processes, Anticompetitive Practices and Consumer Harm in the Software Industry: An Analysis of the Inadequacies of the Microsoft-Department of Justice Proposed Final Judgment (Jan. 25, 2002)
A Roadblock On The Information Superhighway: Anticompetitive Restrictions On Automotive Markets (Consumer Federation of America, February 2001)
Lessons From 1996 Telecommunications Act: Deregulation Before Meaningful Competition Spells Consumer Disaster (Consumer Federation of America, February 2000)
Florida Consumers Need Real Local Phone Competition: Access To Monopoly Wires Is The Key (Consumer Federation of America, January 2001)
The Real Deal: The Comparative Value of Verizons Local Telephone Rates (New Jersey Citizen Action, December 2000)
Maryland Consumers Need Real Local Phone Competition: Fair Access to Monopoly Wires Is the Key (Consumer Federation of America, December 7, 2000)
Bailing Out Of A Bad Business Strategy: Policymakers Should Not Sacrifice Important Public Policies To Save AT&Ts Failed Business Plans (Consumer Federation of America, October 2000)
Setting The Record Straight From A Consumer Perspective On Verizons Radical Rate Restructuring Proposal (Citizen Action, October 2000)
Disconnected, Disadvantaged and Disenfranchised (Consumer Federation of America and Consumers Union, October 11, 2000)
Open Access Phase II (Consumer Federation of America, July 13, 2000)
Who Do You Trust? AOL And AT&T When They ChallengeThe Cable Monopoly Or AOL And AT&T. When They Become The Cable Monopoly?, (Consumer Federation of America, Consumers Union and Media Access Project, February 2000)
Monopoly Power, Anticompetitive Business Practices and Consumer Harm in the Microsoft Case (Consumer Federation of America, December 1999)
Keeping the Information Superhighway Open for the 21st Century (Consumer Federation of America, December 1999)
Creating Open Access to the Broadband Internet: Overcoming Technical and Economic Discrimination in Closed, Proprietary Network (Consumer Federation of America, December 1999)
The Consumer Harm Caused By The Microsoft Monopoly: The Facts Speak For Themselves And They Call For A SternRemedy (Consumer Federation of America, November 1999)
A Consumer Perspective On Economic, Social And Public Policy Issues In The Transition To Digital Television: Report Of The Consumer Federation Of America To People For Better TV (Consumer Federation of America, October 29, 1999)
Transforming the Information Superhighway into a Private Toll Road: Ma Cable and Baby Bell Efforts to Control the High-Speed Internet (Consumer Federation of America, October 1999)
Transforming the Information Superhighway into a Private Toll Road: The Case Against Closed Access Broadband Internet Systems (Consumer Federation of America and Consumer Action, Sept. 20, 1999)
Breaking the Rules: AT&Ts Attempt to Buy a National Monopoly in Cable TV and Broadband Internet Services (Consumer Federation of America, Consumers Union and Media Access Project, Aug. 17, 1999)
Economic Evidence in the Antitrust Trial: The Microsoft Defense Stumbles Over the Facts (Consumer Federation of America, March 18, 1999)
The Consumer Cost of the Microsoft Monopoly: $10 Billion of Overcharges and Counting (Consumer Federation of America, Media Access Project and U.S. PIRG, January1999)
The Digital Divide (Consumer Federation of America and Consumers Union, February 1999)
The Consumer Case Against the SBC-Ameritech Merger (Consumer Federation, et. al, January 20, 1999)
The Consumer Case Against Microsoft (Consumer Federation of America, October 1998)
The Need for Telephone Lifeline Programs in New Jersey: An Update (Center for Media Education and the Consumer Federation of America, July 1998)
Competition in Local Markets: Is the Glass 98 Percent Empty or 2 Percent Full (Consumer Federation of America, February 17, 1998)
10 Two Years After the Telecom Act: A Snapshot of Consumer Impact (Consumer Federation of America, January 21, 1998)
Stonewalling Local Competition: The Baby Bell Strategy to Subvert the Telecommunications Act of 1996 (Consumer Federation of America, January 1998)
The Need for Telephone Lifeline Programs in Kentucky (Kentucky Youth Advocates and Center for Media Education, October 1997)
Money for Nothing: The Case Against Revenue Replacement in the Transition to Local Exchange Competition: A Consumer View of the Gap Between Efficient Prices and Embedded Costs, American Association of Retired Persons, Consumer Federation of America, Consumers Union, January 1997 Low Income Children and the Information Superhighway: Policies for State Public Service Commissions After the Telecommunications Act of 1996, Prepared for the Alliance for South Carolinas Children, January 1997 Excess Profits and the Impact of Competition on the Baby Bells, Consumer Federation of America, September 1996 Universal Service: An Historical Perspective and Policies for the 21st. Century, Benton Foundation and the Consumer Federation of America, August 1996 A Consumer View of Missouri Telephone Legislation: House Bill 1363 Would Mandate Consumer Overcharges and Telephone Company Excess Profits, Consumer Federation of America, March 20, 1996 Evolving Notions of Universal Service (Consumer Federation of America, October 18, 1996)
Economic Concentration and Diversity in the Broadcast Media: Public Policy and Empirical Evidence, December 1995 Federal Deregulation and Local Telephone and Cable TV Rates: Rate Shock in the 1980s and Prospects in the 1990s, November 1995 Basic Service Rates and Financial Cross-Subsidy of Unregulated Baby Bell Activities: The Importance of Effective Competition for Local Service Before Deregulation of Profits and Cross-Ownership, October, 1995 Federal Policy and Local Telephone and Cable TV Rates: Rate Shock in the 1980s and Prospects for the 1990S, October 1995 Mergers and Deregulation on the Information Superhighway: The Public Takes a Dim View: Results of a National Opinion Poll, September 1995 Competition and Consumer Protection in the Florida Telecommunications Legislation, Prepared for the Florida Office of the People's Counsel, April 1995 The Meaning of the Word Infrastructure, June 30, 1994 Protecting the Public Interest in the Transition to Competition in Network Industries, June 14, 1994 Local Exchange Costs and the Need for A Universal Service Fund: A Consumer View, May 1994 Milking the Monopoly: Excess Earnings and Diversification of the Baby Bells Since Divestiture, February 1994 A Consumer Road Map to the Information Superhighway: Finding the Pot of Gold at the End of the Road and Avoiding the Potholes Along the Way, January 26, 1994 Consumers with Disabilities in the Information Age: Public Policy for a Technologically Dynamic Market Environment, 1993 Selling Information Services During 800 and 900 Number Calls: The Need for Greater Consumer Protection, October 2, 1992 The Economics of Deregulation and Reregulation in the Cable Industry: A Consumer View, September 1992 Developing the Information Age in the 1990s: A Pragmatic Consumer View, June 8, 1992 Divestiture Plus Eight: The Record of Bell Company Abuses Since the Break-up of AT&T, December 1991 Transmission Planning, Citing, and Certification in the 1990s: Problems, Prospects and Policies, August 1990 Expanding the Information Age for the 1990s: A Pragmatic Consumer Analysis, January 11, 1990 Divestiture Plus Five: Residential Telephone Service Five Years After the Breakup of AT&T, December 1988 Public Opinion About Deregulation and Regulation in the Transportation and Communications Industries, May 1988 Telecommunications Policy Regarding Deregulation, May 1988 Universal Telephone Service in Ohio: A Review of Recent Evidence, November 12, 1987 The Role of Natural Gas in Solving the Clean Air Problem: Reconciling Consumer and Environmental Interests, April 19, 1988 Divestiture Plus Four: Take the Money and Run, December 1987 The Telecommunications Needs of Older, Low Income and General Consumers in the Post-Divestiture Era, October 1987 Bulk Commodities and the Railroads After the Staggers Act: Freight Rates, Operating Costs and Market Power, October 1987 Divestiture Plus Three: Still Crazy After All These Years, December 1986 Low Income Households in the Post Divestiture Era: A study of Telephone Subscribership and Use in Michigan, October 1986 Sorry Wrong Numbers: Federal Agency Analyses of Telephone Subscribership in the Post-Divestiture Era, February 1986 Industrial Organization and Market Performance in the Transportation and Communications Industries, July 1985 Ringing Off the Wall: An Alarming Increase in Residential Phone Rates, 1984-986, May 12, 1985 Divestiture: One Year Later, December 19, 1984 OTHER Books and Chapters The Transformation of Egypt: State and State Capitalism in Crisis (Baltimore: Johns Hopkins University Press, 1982)
"Egyptian State Capitalism In Crisis: Economic Policies and Political Interests," in Talal Asad and Roger Owen (Eds.), Sociology of Developing Societies: The Middle East (London: Macmillan Press, 1983). First published in The International Journal of Middle Eastern Studies, X:4, 1979
11 "Revoluciones Semi-legalesen el Mediterraneo," in Jesus De Miguel (Ed.), Cambio Social en La Europa Mediterranea (Barcelona: Ediciones Peninsula, 1979). First presented as "The Structure of Semi-legal Revolutions: Between Southern Mediterranean and Western European Patterns," 9th World Congress of the International Sociological Society, Uppsala, Sweden, August, 1978 Articles and Papers The Failure of Market Fundamentalism: What Are The Issues In The ICT Sector? The New Economics of ICT: Implications of Post-Neoclassical Economics for the Information Communications Technology Sector, Columbia University, March 20, 2009 Restoring the Balance of PublicValues and Private Incentives in American Capitalism, Too Much Deregulation or Not Enough, Cato Institution, November 1, 2002 Freeing Public Policy From The Deregulation Debate: The Airline IndustryComes Of Age (And Should Be Held Accountable For Its Anticompetitive Behavior), American Bar Association, Forum On Air And Space Law, The Air and Space Lawyer, Spring 1999 "An Uninformed Purchase," Best's Review: Life/Health Insurance Edition, July 1987 "The Trouble with the ICC and the Staggers Act," Pacific Shipper, June 1, 1987 "The Leftist Opposition in Egypt," Conference on Sadat's Decade: An Assessment, conducted by the Middle Eastern Studies Program of the State University of New York at Binghamton, April, 1984 "The Crisis in the Rental Housing Market: Energy Prices, Institutional Factors and the Deterioration of the Lower Income Housing Stock," 53rd Annual Meeting of the Eastern Sociological Society, March, 1983 "State Capitalism and Class Structure in the Third World: The Case of Egypt," International Journal of Middle East Studies, XIV:4, 1983 "The Militarization and Demilitarization of the Egyptian Cabinet," International Journal of Middle East Studies, XIII: 2, 1982 "Sociological Theory and Economic History: The Collegial Organizational Form and the British World Economy," 51st Annual Meeting of the Eastern Sociological Society, March, 1981 "The Failure of Health Maintenance Organizations: A View from the Theory of Organizations and Social Structure," 50th Annual Meeting of the Eastern Sociological Society, March, 1980 "Impact of Incentive Payments and Training on Nursing Home Admissions, Discharges, Case Mix and Outcomes," Massachusetts Sociological Society, November, 1979 "The State as an Economic Environment," 7th Annual New England Conference on Business and Economics, November, 1979 "The Domestic Origins of Sadat's Peace Initiative," Yale Political Union, March, 1979 "State Capitalism and Class Structure: The Case of Egypt," 49th Annual Meeting of the Eastern Sociological Society March, 1979 "The Welfare State and Equality: A Critique and Alternative Formulation from a Conflict Perspective," 48th Annual Meeting of the Eastern Sociological Society, April, 1978 "A Comparative Evaluation of Operation Breakthrough," Annual Meeting of the Environmental Research Design Association, April, 1975 "Plural Societies and Conflict: Theoretical Considerations and Cross National Evidence," International Journal of Group Tensions, IV:4, 1974.
First presented at the 44th Annual Meeting of the Eastern Sociological Society, March, 1974 "Racialism and Pluralism: A Further Dimensional Analysis," Race and Class, XV:3, 1974 Personality Correlates of Technology and Modernization in Advanced Industrial Society (with Ed Dager), 8th Annual Meeting of the International Sociological Society, August, 1974 "Toward a Model of Conflict in Minority Group Relations," Annual Meeting of the District of Columbia Sociological Society, May, 1973 "A Re-evaluation of the Causes of Turmoil: The Effects of Culture and Modernity," in A Reader in Collective Behavior and Social Movements (F.E. Peacock: New York, 1978). First published in Comparative Political Studies, VII:3, 1974. First presented at the 43rd Annual Meeting of the Eastern Sociological Society, March, 1973 "The Occurrence of Mutiny in World War I: A Sociological View," International Behavioral Scientist, IV:3, 1972 RESEARCH REPORTS WITH BARBARA ROPER, REFORM OF FINANCIAL MARKETS: THE COLLAPSE OF MARKET FUNDAMENTALISM AND THE FIRST STEPS TO REVITALIZE THE ECONOMY, APRIL 2009 Credit Unions In A 21st Century Financial Marketplace: Economic And Organizational Underpinnings Of Institutional Success (Consumer Federation of America, 2004)
Unconventional Wisdom: Ten New State Polls Offer a Chance to Rethink How Americans View the Assault Weapons Ban (Consumer Federation of America and the Educational Fund to Stop Gun Violence, July 13, 2004)
Public Opinion About quality, Self-Dealing and Billing for Ancillary Medical Tests, October 17, 1991 A Consumer Perspective on Direct Billing: The Next Step in Reforming the Market for Ancillary Medical Services, July 1991 Clearing the Air on Airline Deregulation, May 22, 1991 Airport Pricing of Access for Off-Premise Auto Rental Companies: The Growing Pattern of Abuse, April 24, 1990 Public Opinion About Health Care Purchases: Cost, Ease of Shopping and Availability, April 27, 1989 Bailing Out the Savings and Loans Who Bears the Burden Under Alternative Financing Approaches, March 9, 1989 Airport Fees for Auto Rental Companies: A Consumer Perspective, June 1988, Reforming the Interstate Commerce Commission: Getting the Facts Straight, February 10, 1988 The Benefits of the Modernization of the Tort Law in the Context of the Social Movement for Improved Safety and Quality in the National Economy, September 1987 The Potential Costs and Benefits of Allowing Banks to Sell Insurance, February 10, 1987
12 Confusion and Excess Cost: Consumer Problems in Purchasing Life Insurance, January 21, 1987 The Costs and Benefits of Exclusive Franchising: The Case of Malt Beverages, September 17, 1986 Punitive Damages in Product Liability Cases: Setting the Record Straight, September 1986 Local Rate Increases in the Post-Divestiture Era, Excessive Returns to Telephone Company Capital, September 1986 Trends in Liability Awards: Have Juries Run Wild, May 1986 Farm worker Demographics, National and State Planning Packages, May 1986 The Great Train Robbery: Electric Utility Consumers and the Unregulated Rail Monopoly Over Coal Transportation, Overview, The Rail Monopoly Over Bulk Commodities, A Continuing Dilemma for Public Policy, August 1985 Deregulation of the Dairy Industry, November 1983 Meal Production Costs in School Food Kitchens: An Economic Analysis of Production Processes and Efficiencies, December 1981 A Study of Program Management Procedures in the Campus-based and Basic GRANTS Programs: Final Report, March 1980 A Study of Program Management Procedures in the Campus-based and Basic Grants Programs: Site Visit Report, December 1975 A Comparative Evaluation of Operation Breakthrough, Chapter 3, August 1975 Judging the Merits of Child Feeding Programs, 1975 A Comparative Evaluation of Ongoing Programs in Columbia, Kenya, and the Philippines, 1974 TESTIMONY:
FEDERAL AGENCIES AND COURTS Comments of Dr. Mark Cooper. In the Matter of Carbon Pollution Emission Guidelinesfor Existing Stationary Sources: Electric Utility Generating Units, Environmental Protection Agency, RIN 2060-AR33, November 24, 2015.
Nuclear Power Is an Expensive, Inferior Resource That Has No Place in a Least-Cost, Low-Carbon Portfolio. Submission to the Electricity Generation from Nuclear Fuels, Nuclear Fuel Cycle Royal Commission, August 3, 2015.
Comments Of The Consumer Federation Of America, In the Matter of Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auction Revisions to Rules Authorizing the Operation of Low Power Auxiliary Stations in the 698-806 MHz Band, Public Interest Spectrum Coalition, Petition for Rulemaking Regarding Low Power Auxiliary Stations, Including Wireless Microphones, and the Digital Television Transition, Amendment of Parts 15, 74 and 90 of the Commissions rule, Regarding Low Power Auxiliary Stations, Including Wireless, Federal Communications Commission, Docket No.12-268 ET, WT Docket No.08-166, WT Docket No.08-167, Docket No. 10-24, January 25, 2013 American Federalism At Its Best: Why The Environmental Protection Agency Should Grant A Clean Air Act Waiver To California For Its Advanced Clean Cars Program, Environmental Protection Agency, September 19, 2012 Comments of the Consumer Federation of America on Proposed Final Judgment as to Defendants Hachette, HarperCollins and Simon &
Schuster, United States v. Apple, Inc., et al., 12-cv-2826 (DLC) (SDNY), United States District Court For the Southern District of New York, June 25, 2012, Comments Of Consumer Groups, Proposed Rule 2017 And Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, Docket Nos., EPA-HQ-OAR-2010-0799; FRL-9495-2, NHTSA 2010-0131, February 13, 2012 Statement Of Dr. Mark Cooper, Director Of Research, Joint NHTSA-EPA Hearings On Fuel Economy Standards For 2017-2025, January 2012 Statement Of Dr. Mark Cooper, Director Of Research, Consumer Federation Of America to The Federal Communications Commission Broadband Workshop On The Unserved And Underserved, August 12, 2009 Comment Of The Consumer Federation Of America In The Matter Of Applications Of Cellco Partnership C/B/A Verizon Wireless And SpectrumcoLLC For Consent To Assign Licenses, WT Docket No.12-4, Application Of Cellco Partnership D/B/A, Verizon Wireless And Cox TMI Wireless, LLC For Consent To Assign Licenses, July 9, 2012, Letter Urging Close Scrutiny Of UMG-EMI Merger, Subcommittee On Antitrust, Competition Policy And Consumer Rights, United States Senate, Committee On The Judiciary, April 26, 2012 Comments Of The Consumer Federation Of America To The U.S. Department Of Commerce Internet Policy Task Force, Docket No.
101214614061401, RIN 0660XA22, Information Privacy And Innovation In The Internet Economy, January 28, 2011 Comments of the Consumer Federation of America on the Proposed Horizontal Merger Guidelines, Before the Federal Trade Commission, FTC File No. PO92700, June 4, 2010 Reply Comments -- National Broadband Plan, Public Notice #30, Center for Media Justice, Consumer Federation of America, Consumers Union, Open Technology Initiative, Public Knowledge, on Broadband Adoption, Before the Federal Communications Commission, In the Matter of A National Broadband Plan for Our Future, GN Docket No. 09-47, 09-51,09-137, January 27, 2010 Comments of the Consumer Federation of America, before the Environmental Protection Agency and Department of Transportation, Proposed Rulemaking to Establish Light-Duty Vehicles Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, November 27, 2009 Statement of Mark Cooper to the Joint SEC-CFTC Meeting on Harmonization of Regulation, September 2, 2009.
Comments of The Consumer Federation Of America On November 2008 Report Of L.R. Christensen Associates, Inc. United States Of America, Surface Transportation Board, Ex Parte No. 680, Study Of Competition In The Freight Rail Industry, December 22, 2008 Comments on the Draft Environmental Impact Statement of Consumer Federation of America, et al., Notice of Proposed Rulemaking: Average Fuel Economy Standard; Passenger Cars and Light Trucks, Model Years 2011-2015, August 18, 2008
13 Comment and Technical Support Appendices of the Consumer Federation of America, Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, July 1, 2008 Behavioral Marketing Principles, with Susan Grant, Federal Trade Commission, April 10, 2008 Reply Comments of Consumer Federation of America and Consumers Union, In the Matter of the Petition of Free Press, et al. for Declaratory Ruling that Degrading an Internet Application Violates the FCCs Internet Policy Statement and Does not Met an Exception for Reasonable Network Management, and Vuze, Inc. to Establish Rule Governing Network Management Practices by Broadband Network Operators, Broadband Industry Practices, Commercial Availability of Navigation Devices, WC Docket No. 07-52, CS Docket No. 97-80, February 28, 2008 Comments on Behavioral Tracking and Targeting, Federal Trade Commission, Town Hall Meeting on Ehavioral Advertising: Tracking, Targeting and Technology, November 16, 2007 Comments of the Consumer Federation of America, Consumers Union and Free Press, In the Matter of Broadband Industry Practices, WC Docket No. 07-52, June 15, 2007 Petition to Deny of Common Cause, Consumer Federation of America, Consumers Union and Free Press, In the Matter of Consolidated Application for Authority to transfer Control of XM Sirius Radio Inc, and Sirius Satellite Radio Inc, MB Docket No. 07-57, July 9, 2007 Comment of the Texas Office of Public Utility Counsel, Consumer Federation of America and Consumers Union, In the Matter of Intercarrier Compensation, CC Docket No. 91-92, October 25, 2006 Statement, Local Hearing, Federal Communications Commission, Los Angeles, October 2006 Affidavit, with Trevor Roycroft, In the Matter of Review of AT&T Inc. and BellSouth Corporation, Application for Consent to Transfer of Control, WC Docket No. 06-74.
Comments and Reply Comments of the Consumer Federation Of America and Consumers Union In Opposition To The Transfer Of Licenses, Applications of Adelphia Communications Corporation, Comcast Corporation and Time Warner Cable Inc., For Authority to Assign and/or Transfer Control of Various Licenses, Before the Federal Communications Commission, MM Docket No.05-192 Comments of Consumer Federation of America, Consumers Union and Free Press, In the Matter of the Commissions Cable Horizontal and Vertical Ownership Limits and Attribution Rules, MM Docket No.92-264, August 8, 2005 Petition to Deny of the Consumer Federation of America, Consumers Union, and USPIRG, In the Matter of Applications of SBC Communications Inc. and AT&T Corporation to Transfer Control of Section 214 and 308 Licenses and Authorizations and Cable Landing Licenses, WC Docket No. 05-65, April 25, 2005 Petition to Deny of the Consumer Federation of America, Consumers Union, and USPIRG, In the Matter of Applications of Verizon Communications Inc. and MCI Inc. Applications for Approval of Transfer of Control of Section, WC Docket No. 05-75, May 9, 2005 Comments of the Consumer Federation of America and Consumers Union, before the Federal Communications Commission, In the Matter of Broadcast Localism MB Docket No.04-233, November 1, 2004 Comments and Reply Comments of Dr. Mark Cooper on Behalf of the Texas Office of Public Utility Counsel and the Consumer Federation of America, before the Federal Communications Commission, In the Matter of Final Unbundling Rules, Docket Nos. WC-04-313, CC-01-338, October 4, October 19, 2004.
Comments and Reply Comments of Consumers Union and the Consumer Federation of America, In the Matter of Comments Requested on a La Carte and Themed Tier Programming and Pricing Options for Programming Distribution on Cable Television and Direct Broadcast Satellite Systems, before the Federal Communications Commission, MB Docket No.04-207, July 13, 2004, August 13, 2004 Affidavit of Mark Cooper, Prometheus Radio Project, et al. v. Federal Communications Commission and United States of America, No. 03-3388, et al., August 6, 2004 Comments Of Consumer Federation Of America and Consumers Union, In The Matter Of IP-Enabled Services, Petition Of SBC Communications Inc. For Forbearance, Before The Federal Communications Commission, WC Docket No. 04-29, 04-36, July 14, 2004 Testimony of Mark Cooper, before the Federal Energy Regulatory Commission, Solicitation Processes for Public Utilities, June 10, 2004 Petition to Deny and Reply to Opposition of the Consumer Federation of America and Consumers Union, In the Matter of Applications for the Transfer of Control of Licenses and Authorization from AT&T Wireless Services, Inc., and its Subsidiaries to Cingular Wireless Corporation, before the Federal Communications Commission, WT Docket No. 04-70, May3, May 20, 2004 Opposition to the Petitions for Reconsideration, Reply comments of the Consumer Federation of America, In the Matter of Digital Broadcast Content Protection, Implementation of Section 304 of the Telecommunications Act of 1996, Commercial Availability of Navigation Devices, Compatibility Between Cable Systems and Consumer Electronic Equipment, before the Federal Communications Commission, Docket Nos. MB-02-230, CS-97-80, PP-00-67, March 15, 2004 Petition for Reconsideration of the Consumer Federation of America and Consumers Union, In The Matter Of 2002 Biennial Regulatory Review - Review of the Commissions Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996, Cross-Ownership of Broadcast Stations and Newspapers Rules and Policies Concerning Multiple Ownership of Radio Broadcast Stations in Local Market, Definition of Radio Markets, Federal Communications Commission, MB Docket No.02-277, MM Docket Nos.00-244, 01-235,01-317, September 4, 2003 Reply Comments Of Consumer Federation Of America, In the Matter of Second Periodic Review of the Commissions Rules and Policies Affecting the Conversion To Digital Television, Public Interest Obligations of TV Broadcast Licensees, Childrens Television Obligations Digital Television Broadcaster, Standardized and Enhanced Disclosure Requirements for Television Broadcast Licensee, Public Interest Obligations, Before the Federal Communications Commission, MB Docket No. 03-15,RM 9832, MM Docket Nos.99-360, 00-167,00-168, May 21, 2003
14 Reply Comments of the Consumer Federation of America, In the Matter of Digital Broadcast Copy Protection, Federal Communications Commission, MB Docket NO.02-230, February 18, 2003 Comments of Consumer Federation of America, Consumers Union, Center for Digital Democracy, Media Access Project, In The Matter Of 2002 Biennial Regulatory Review - Review of the Commissions Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996, Cross-Ownership of Broadcast Stations and Newspapers Rules and Policies Concerning Multiple Ownership of Radio Broadcast Stations in Local Market, Definition of Radio Markets, Federal Communications Commission, MB Docket No.02-277, MM Docket Nos.00-244, 01-235,01-317, Comments January 3, 2003, Reply Comments February 3, 2003 Comments of the Texas Office of Public Utility Counsel, The Consumer Federation of America, Consumers Union, In the Matter of Petition for Declaratory Ruling that AT&Ts Phone-to-Phone IP Telephony Services are Exempt from Access Charges, Federal communications Commission, WC Docket No.02-361, January 18, 2003 Comments of Arizona Consumers Council, California Public Interest Research Group, Colorado Public Interest Research Group, Columbia Consumer Education Council, Consumer Assistance Council (MA) Consumer Federation of America, Florida Consumer Action Network, Massachusetts Consumers Council, North Carolina Public Interest Research Group, Oregon State Public Interest Research Group, Texas Consumers Association, The Consumers Voice, US Action, Virginias Citizens Consumer Council, In the Matter of Digital Broadcast Copy Protection, Federal Communications Commission, MB Docket NO.02-230, December 6, 2002 Initial Comments of the Consumer Federation of America, Remedying Undue Discrimination through Open Access Transmission Service and Standard Electricity Market Design, Federal Energy Regulatory Commission, Docket No. RM-01-12-000, October 15, 2002 An Economic Explanation of Why the West and South Want to Avoid Being Infected by FERCs SMD and Why Market Monitoring is Not an Effective Cure for the Disease, SMD Market Metrics Conference, Federal Energy Regulatory Commission, October 2, 2002 Bringing New Auto Sales and Service Into the 21st Century: Eliminating Exclusive Territories and Restraints on Trade Will Free Consumers and Competition, Workshop on Anticompetitive Efforts to Restrict Competition on the Internet, Federal Trade Commission, October 7, 2002 Once Money Talks, Nobody Else Can: The Publics first Amendment Assets Should Not Be Auctioned to Media Moguls and Communications Conglomerates, In the Matter of Spectrum Policy Task Force Seeks Public Comment on Issues Related to Commissions Spectrum Policy, Federal Communications Commission, DA 02-1221, ET Docket No.02-135, July 8, 2002 Comments Of The Texas Office Of Public Utility Counsel, Consumer Federation Of America, Consumers Union, Media Access Project, And The Center For Digital Democracy, Federal Communications Commission, In the Matter of Appropriate Framework for Broadband Access to the Internet Over Wireline Facilities Universal Service Obligations of Broadband Providers Computer III Further Remand Proceedings: Bell Operating Company Provision of Enhanced Services; 1998 Biennial Regulatory Review -Review of Computer III and ONA Safeguards And Requirements, CC Dockets Nos. 02-3395-20, 98-10, July 1, 2002 Comments of the Consumer Federation of America, Consumers Union, Center for Digital Democracy, The Office of Communications of the United Church of Christ, Inc., National Association of Telecommunications Officers and Advisors, Association for Independent Video Filmmakers, National Alliance for Media Arts and Culture, and the Alliance for Community Media. Federal Communications Commission, In the Matter of Implementation of Section 11 of the Cable Television Consumer Protection and Competition Act of 1992 Implementation of Cable Act Reform Provisions of the Telecommunications Act of 1996 The Commissions Cable Horizontal and Vertical Ownership Limits and Attribution Rules Review of the Commissions Regulations Governing Attribution Of Broadcast and Cable/MDS Interests Review of the Commissions Regulations and Policies Affecting Investment In the Broadcast Industry Reexamination of the Commissions Cross-Interest Policy, CS Docket No. 98-82, CS Docket No. 96-85, MM Docket No.92-264, MM Docket No.94-150, MM Docket No. 92-51, MM Docket No.87-154 Reply Comments of the Consumer Federation of America, Consumers Union, Center for Digital Democracy, and Media Access Project, in Federal Communications Commission, In the Matter of Implementation of Section 11 of the Cable Television Consumer Protection and Competition Act of 1992 Implementation of Cable Act Reform Provisions of the Telecommunications Act of 1996 The Commissions Cable Horizontal and Vertical Ownership Limits and Attribution Rules Review of the Commissions Regulations Governing Attribution Of Broadcast and Cable/MDS Interests Review of the Commissions Regulations and Policies Affecting Investment In the Broadcast Industry Reexamination of the Commissions Cross-Interest Policy, CS Docket No. 98-82, CS Docket No.
96-85, MM Docket No.92-264, MM Docket No.94-150, MM Docket No. 92-51, MM Docket No.87-154.
Petition to Deny of Arizona Consumers Council, Association Of Independent Video And Filmmakers, CalPIRG, Center For Digital Democracy, Center For Public Representation, Chicago Consumer Coalition, Civil Rights Forum On Communications Policy, Citizen Action Of Illinois, Consumer Action, Consumer Assistance Council, Consumer Federation Of America, Consumer Fraud Watch, Consumers United/Minnesotans For Safe Food, Consumers Union, Consumers Voice, Democratic Process Center, Empire State Consumer Association, Florida Consumer Action Network, ILPIRG (Illinois), Massachusetts Consumers Coalition, MassPIRG, Media Access Project, Mercer County Community Action, National Alliance For Media Arts And Culture, MontPIRG, New York Citizens Utility Board, NC PIRG, North Carolina Justice And Community Development Center, OsPIRG(Oregon State), Oregon Citizens Utility Board, Texas Consumer Association, Texas Watch, United Church Of Christ, Office Of Communication, Inc., US PIRG, Virginia Citizens Consumer Council, WashPIRG, Wisconsin Consumers League, In the Matter of Application for Consent to the Transfer of Control of Licenses Comcast Corporation and AT&T Corporation, Transferors, to AT&T Comcast Corporation, Transferee, April 29, 2002 Tunney Act Comments of Consumer Federation of America, Connecticut Citizen Action Group, ConnPIRG, Consumer Federation of California, Consumers Union, Florida Consumer Action Network, Florida PIRG, Iowa PIRG, Massachusetts Consumers Coalition, MassPIRG, Media Access Project, U.S. PIRG, in the United States v. Microsoft Corp, Civil Action No. 98-1232, (Jan. 25, 2002)
Comments of Consumer Federation of America, et al, In the Matter of Implementation of Section 11 of the Cable Television Consumer Protection and Competition Act of 1992, Implementation of Cable Act Reform Provisions of the Telecommunications Act of 1996, The Commissions Cable Horizontal and Vertical Ownership Limits and Attribution Rules, Review of the Commissions Regulations Governing Attribution of Broadcast and Cable MDS Interests, Review of the Commissions Regulations and Policies Affecting
15 Investment in the Broadcast Industry, Reexamination of the Commissions Cross-Interest Policy, CS Docket Nos. 98-82, 96-85; MM Docket Nos.92-264, 94-150, 92-51,87-154, January 4, 2002.
Comments of Consumers Union, Consumer Federation of America, Civil Rights Forum, Center for Digital Democracy, Leadership Conference on Civil Rights and Media Access Project, before the Federal Communications Commission, In the Matter of Cross Ownership of Broadcast Station and Newspaper/Radio Cross-Ownership Waiver Policy, MM Docket No.01-235, 96-197; December 3, 2001)
Motion To Intervene And Request For Rehearing Of The Consumer Federation Of America, before the Federal Energy Regulatory Commission, San Diego Gas & Electric Company, Complaint, v. All Sellers of Energy and Ancillary Services Into Markets Operated by the California Independent System Operator and the California Power Exchange, Docket Nos. EL00-95-000 et al, Reply Comments of the Consumer Federation Of America, before the Federal Energy Regulatory Commission, San Diego Gas & Electric Company, Complaint, v. All Sellers of Energy and Ancillary Services Into Markets Operated by the California Independent System Operator and the California Power Exchange, Docket Nos. EL00-95-000 et al, Reply Comments Of Texas Office Of Public Utility Counsel, Consumer Federation Of America, Consumers Union, Federal Communications Commission, In The Matter Of Inquiry Concerning High Speed Access To The Internet Over Cable And Other Facilities, GN Docket No.00-185, January 11, 2001 Comments Of Texas Office Of Public Utility Counsel, Consumer Federation Of America, Consumers Union, Federal Communications Commission, In The Matter Of Inquiry Concerning High Speed Access To The Internet Over Cable And Other Facilities, GN Docket No.00-185, December 1, 2000 Statement before the en banc Hearing in the Matter of the Application of America Online, Inc. and Time Warner, Inc. for Transfer of Control, Federal Communications Commission, July 27, 2000 Petition to Deny of Consumers Union, the Consumer Federation of America, Media Access Project and Center for Media Education, In the Matter of Application of America Online, Inc. and Time Warner for Transfer of Control, CS 00-30, April 26, 2000 Comments Of The Consumer Federation Of America, In the Matter of Application of SBC Communications Inc. and Southwestern Bell Telephone Company and Southwestern Bell Communications Services, Inc. D/B/A Southwestern Bell long Distance for Provision of In-Region, InterLATA Services in Texas, Before the Federal Communications Commission, CC Docket No. 00-4, February 28, 2000 Consumer Federation Of America, Request For Reconsideration Regional Transmission Organizations, Federal Energy Regulatory Commission, Docket No. RM99-2-000; Order No. 2000, January 20, 2000 Reply Comments Of Texas Office Of Public Utility Counsel Consumer Federation Of America Consumers Union (Joint Consumer Commentors), In the Matter of Access Charge Reform Price Cap Performance Review for Local Exchange Carriers Low Volume Long Distance Users Federal-State Joint Board On Universal Service, Before The Federal Communications Commission, CC Docket No.96-262, CC Docket No. 94-1, CC Docket No.99-249, CC Docket No. 96-45, December 3, 1999.
Reply Comments Of The Consumer Federation Of America, Consumers Union, and AARP, Proposed Transfer Of Control SBC And Ameritech, Before the Federal Communications Commission, Cc Docket No.98-141, November 16, 1999 Comments Of Texas Office Of Public Utility Counsel Consumer Federation Of America Consumers Union (Joint Consumer Commentors), In the Matter of Access Charge Reform Price Cap Performance Review for Local Exchange Carriers Low Volume Long Distance Users Federal-State Joint Board On Universal Service, Before The Federal Communications Commission, CC Docket No.96-262, CC Docket No. 94-1, CC Docket No.99-249, CC Docket No. 96-45, November 12, 1999.
Reply Comments Of Texas Office Of Public Utility Counsel Consumer Federation Of America Consumers Union (Joint Consumer Commentors), In the Matter of Low Volume Long Distance Users Federal-State Joint Board On Universal Service, Before The Federal Communications Commission, CC Docket No.99-249, October 20, 1999.
Comments Of The Consumer Federation Of America, In the Matter of Application of New York Telephone Company (d/b/a/ Bell Atlantic -
New York, Bell Atlantic Communications, Inc. NYNEX Long Distance Company and Bell Atlantic Global Networks, Inc., for Authorization To Provide In-Region, InterLATAServices in New York, Before the Federal Communications Commission, CC Docket No.99-295, October 20, 1999 Comments Of Texas Office Of Public Utility Counsel Consumer Federation Of America Consumers Union (Joint Consumer Commentors), In the Matter of Low Volume Long Distance Users Federal-State Joint Board On Universal Service, Before The Federal Communications Commission, CC Docket No.99-249, September 20, 1999 Reply Comments of Consumer Federation of America on Joint Petition for Waiver, before the Federal Communications Commission, In the Matter of Implementation of the Subscriber Carrier Selection Changes Provision of the Telecommunications Act of 1996, Policies and Rule Concerning Unauthorized Changes of Consumers Long Distance Carriers, CC Docket NO.94-129, FCC 98-334 Joint Comments of Texas Office Of Public Utility Counsel Consumer Federation Of America National Association Of State Utility Consumer Advocates Consumers Union, In the Matter of Federal-State Joint Board On Universal Service Access Charge Reform Before The Federal Communications Commission, Before The Federal Communications Commission, CC Docket No. 96-45, CC Docket No.96-262, July 23, 1999 Affidavit of Dr. Mark N. Cooper on Behalf of Consumer Intervenors, RE: In the Matter of Applications for Consent to the Transfer Of Control of Licenses and Section 214 Authorizations from Ameritech Corporation, Transfer, to SBC Communications Inc., Transferee, Before The Federal Communications Commission, CC Dkt. No.98-141, July 17, 1999.
Reply comments of the Consumer Federation of America, Consumers Union and AARP, before the Federal communications Commission, before the Federal Communications Commission, Proposed Transfer of Control SBC and Ameritech, CC Docket No.98-141, November 16, 1998.
Comments and Reply Comments of the Consumer Federation of America, International Communications Association and National Retail Federation Petition, before the Federal Communications Commission, In the Matter of Access Charge Reform, Price Cap Performance Review for Local Exchange Carriers, Consumer Federation of America, International Communications Association and National Retail Federation Petition Requesting Amendment of the Commissions Rules Regarding Access Charge Reform and Price
16 Cap Performance Review for Local Exchange Carriers, Federal Communications Commission, CC Docket Nos.96-262, 94-1, RM9210, October 25, 1998, November 9, 1998.
Letter to William E. Kennard, on behalf of The Consumer Federation of America, in Reciprocal Compensation of Internet Traffic, November 5, 1998.
Preserving Affordable Basic Service Under the 96 Telecom Act, to the Federal Communications Commission and the Federal-State Joint Board, October 29, 1998.
Reply Comments Of The Consumer Federation Of America And Consumers Union, before The Federal Communications Commission. In The Matter Of Deployment Of Wireline Services Offering Advanced Telecommunications Capability, Etc., CC Docket Nos.98-147, 98-11 98-26, 98-32, 98-78, 98-91, CCB/CPD Docket N. 98-15 RM 9244, October 16, 1998 The Impact of Telephone Company Megamergers on the Prospect for Competition in Local Markets, before the Federal communications Commission, before the Federal Communications Commission, Proposed Transfer of Control SBC and Ameritech, CC Docket No.98-141, October 15, 1998 The Impact of Telephone Company Megamergers on the Prospect for Competition in Local Markets, Comments of The Consumer Federation of America and Consumers Union, before the Federal communications Commission, before the Federal Communications Commission, Proposed Transfer of Control SBC and Ameritech, CC Docket No.98-141, October 15, 1998 Letter to William E. Kennard, on Behalf of the Consumer Federation of America, in Re: Pass through of Access Charge Reductions, August 13, 1998.
Statement of Dr. Mark N. Cooper, on behalf of the Consumer Federation of America, In the Matter of Federal-State Joint Board On Universal Service Forward Looking Mechanisms for High Cost Support for Non-Rural LECs, June 8, 1998.
Reply Comments of Consumers Union and the Consumer Federation of America, before the Federal Communications Commission, In the Matter of Consumer Federation of America, International Communications Association and National Retail Federation Petition Requesting Amendment of the Commissions Rules Regarding Access Charge Reform and Price Cap Performance Review for Local Exchange Carriers, Federal Communications Commission, Docket No. RM9210, February 17, 1998 Statement of Dr. Mark N. Cooper, on Behalf of the Consumer Federation of America, Before the Federal Communications Commission, Re:
Cable TV Rates, December 18, 1997.
Letter to William Kennard, on Behalf of The Consumer Federation of America, Re: Long Distance Basic Rates, November 26, 1997.
Letter to William E. Kennard, on behalf of the Consumer Federation of America, Re; Proposed Revision of Maximum Collection Amounts for Schools and Libraries and Rural Health Care Providers, Public Notice, CC Docket No. 96-45; DA 98-872, May 21, 1998.
Reply Comments of Consumers Union and the Consumer Federation or America, In the Matter of Consumer Federation or America, International Communications Association and National Retail Federation Petition Requesting Amendment of the Commissions Rules Regarding Access Charge Reform and Price Cap Performance Review for Local Exchange Carriers, Federal Communications Commission, Docket No. RM9210, February 17, 1998.
Reply Comments of the Consumer Federation of America, In the Matter of Application by BellSouth Corporation, BellSouth Telecommunications, Inc., and BellSouth Long Distance, Inc., for Provision of In-Region, InterLATA Services in Louisiana, Federal Communications Commission, CC Docket No.97-231, December 19, 1997 Letter to Reed Hundt, on Behalf of the Consumer Federation of America, Re: CC Docket NO. 92-237: Carrier Identification Codes, October 15, 1997 Statement of Dr. Mark N. Cooper, on Behalf of the Consumer Federation of America, before the Federal Communications Commission, In Re:
Petition of Consumers Union and the Consumer Federation of America to Update Cable TV Regulation and Freeze Existing Cable Television Rates, MM Docket Nos.92-264, 92-265,92-266, September 22, 1997 Reply Comments of Consumer Federation of America and Consumer Action on Remand Issues in the Pay Telephone Proceeding, Federal Communications Commission, In the Matter of Implementation of the Pay Telephone Reclassification and Compensation Provisions of the Telecommunications Act of 1996, CC Docket NO.96-128, DA 97-1673 (Remand), September 9, 1997.
Letter to Reed Hundt, Consumer Federation of America, Re: Ameritech 271 Application for Michigan, CC Docket No.97-137, August 11, 1997.
Statement of Dr. Mark N. Cooper, Federal Communications Commission, Hearing on Cable Television Competition and Rates, December 18, 1997 Reply Comments of the Consumer Federation of America, In the Matter of Application by BellSouth Corporation, et. al. For Provision of In-Region, InterLATA Services in South Carolina, Federal Communications Commission, CC Docket No.97-208, November 14, 1997 Statement of Dr. Mark N. Cooper, In Re: Petition of Consumers Union and the Consumer Federation of America to Update Cable TV Regulation and Freeze Existing Cable Television Rates, Federal Communications Commission, September 22, 1997.
The Telecommunication Act of 1996: The Impact on Separations of Universal Service and Access Charge Reform, before the Federal State Joint Board on Separations, February 27, 1997 Comments of the Consumer Federation of America, before the Federal Communications Commission In the Matter of Federal-State Joint Board on Universal Service, CC Docket No. 96-45, August 2, 1996 In the Matter of Allocation of Costs Associated with Local Exchange Carrier Provision of Video Programming Services, before the Federal Communications Commission, In the Matter of Allocation of Costs Associated with Local Exchange Carrier Provision of Video Programming Services, CC Docket No.96-122, June 12, 1996 Comments of Consumer Federation of America, before the Federal Communications Commission, In the Matter of the Local Competition Provisions of the Telecommunications Act of 1996, 1996 "Statement of Dr. Mark N. Cooper," Before the Federal Communications Commission, In Re: Review of the Commission's Regulations Governing Television Broadcasting, MM Docket No.91-221, July 10, 1995
17 "Cost Analysis and Cost Recovery on the Information Superhighway, Evidence of Dr. Mark N. Cooper on behalf of the National Anti-poverty Organization and Federation Nationale des Associations Consumateurs du Quebec," before the Canadian Radio-Television and Telecommunications Commission, Review of Regulatory Framework, Public Notice CRTC 92-78, April 13, 1995 "Affidavit in Support of the Petition for Relief of the Center for Media Education, Consumer Federation of America, the United Church of Christ, the National Association for the Advancement of Colored People, and the National Council of La Raza, May 24, 1994 "Response of the Consumer Federation of America and the Center for Media Education to Bell Atlantic's Request for an Expedited Waiver Relating to Out-of-Region Interexchange Services and Satellite Programming Transport," Department of Justice, In Re: United States of America v. Western Electric Company, Inc., and American Telephone and Telegraph Company, Civil No. 82-0192 (HHG), March 8, 1994 "Petition to Deny: Center For Media Education and Consumer Federation of America," before the Federal Communications Commission, In the Matter of the Application of U.S. West Communications Inc., for Authority Under Section 214 of the Communications Act of 1934, as Amended, to Construct, Operate Own and Maintain Facilities and Equipment to Provide Video Dialtone Service in Portions of the Denver, Portland, Oregon, and Minneapolis -St. Paul Service Area, March 4, 1994 "Comments of the Consumer Federation of America," before the Federal Communications Commission, In the Matter of Implementation of Sections of the Cable Television Consumer Protection Act of 1992, MM Docket No.92-266, January 27, 1993 "Evidence of Mark N. Cooper: Submission of the National Anti-poverty Organization," before the Canadian Radio-Television and Telecommunications Commission, Review of Regulatory Framework, Public Notice CRTC 92-78, April 13, 1992 "Comment of Mark N. Cooper on Behalf of the Center for Science in the Public Interest," before the Food and Drug Administration, In the Matter of Regulatory Impact Analysis of the Proposed Rule to Amend the food and Labeling Regulations, Docket No. 91N-0219, February 25, 1992 "Comment of Mark N. Cooper on Behalf of the Center for Science in the Public Interest," before the U.S. Department of Agriculture, In the Matter of Preliminary Regulatory Impact Analysis of the Proposed Regulations for Nutrition Labeling of Meat and Poultry, Docket No.91-006, February 25, 1992 "Comment of the Consumer Federation," before the Federal Communications Commission, In the Matter of Rules and Policies Regarding Calling Number Identification Service, CC Docket No.91-281, January 1992 "Comments of the Consumer Energy Council of America Research Foundation," before the Environmental Protection Agency, 40 CFR Part 73, December 12, 1991 "Comments of the Consumer Energy Council of America Research Foundation," before the Environmental Protection Agency, 40 CFR Part 73, July 5, 1991 "Affidavit of Dr. Mark N. Cooper on Abuse of the Monopoly Franchise by the Regional Bell Operating Companies in the Marketing of Optional Services," United States District Court for the District of Columbia, United States of America v. Western Electric Company and American Telephone and Telegraph Company, C.A. No. 82-0192, October 17, 1990 "Health Claims in Food Labeling and Advertising: Reexamining the Public Interest After Two Decades of Dispute," Food and Drug Administration, Food Labeling: Advanced Notice of Proposed Rule making, January 5, 1990 "Comments of the Consumer Federation of America, in the Matter of Medicare and Medicaid Programs: Fraud and Abuse OIG Anti-Kickback Provisions, 42 CFR Part 1001, Department of Health and Human Services, March 24, 1989 "Comments of the Consumer Federation of America in the Matter of Railroad Cost Recovery Procedures -- Productivity Adjustment, Ex Parte No. 290 (Sub-No. 4), Interstate Commerce Commission, December 16, 1988 "Answer of the Consumer Federation of America to the Petition of International Flight Attendants," U.S. Department of Transportation, Docket N. 45792, September 20, 1988 "Joint Comments of the Consumer Federation of America and the Environmental Action Foundation," Federal Energy Regulatory Commission, Dockets Nos. RM88-4, 5,6-000, July 18, 1988 "Comments of the Consumer Federation of America in Opposition to the Request to Reopen and Set Aside Consent Order," Federal Trade Commission, Docket No. 9033, July 5, 1988 "Comments of the Consumer Federation of America on the Initiation of National Security Investigations of Imports of Crude Oil and Refined Petroleum Products," Notice of Investigation Under Section 232 of the Trade Expansion Act of 1962, U.S. Department of Commerce, January 28, 1988 "Policies and Rules Concerning Dominant Carriers: The FCC's Price Cap Proposal," Federal Communications Commission, CC. Docket No.87-313, October 19, 1987 "On Behalf of the Consumers' Association of Canada," Re: CRTC Telecomm Public Notice 187-15, Bell Canada and British Columbia Telephone Company: Rate Rebalancing and Revenue Settlement Issue, Before the Canadian Radio-Television Commission, August 21, 1987 "Comments of the Consumer Federation of America on the Department of Energy's Study of the Impact of Falling Oil Prices on Crude Oil Production and Refining Capacity in the United States, U.S. Department of Energy, November 30, 1986 "Comments of the Consumer Federation of America on the Notice of Proposed Rule making Issued May 30, 1985," before the Federal Energy Regulatory Commission, Docket No. RM85-1-000 (Part A-D), July 15, 1985 "Comments of the Consumer Federation of America and U.S. Public Interest Research Group, in the Matter of MTS and WATS Market Structure and Amendment of Part 67 of the Commission's Rules and Establishment of a Joint Board" Before the Federal Communications Commission, CC Docket Nos. 78-72 and 80-286, April 26, 1985 "On Behalf of the California Human Development Corporation, et al., v. Raymond L. Donovan, Secretary, U.S. Department of Labor," United States District Court for the District of Columbia, Case No. 83-3008, March 20, 1984 "Utility Fuels, Inc. v. Burlington Northern Railroad Co., Fort Worth and Denver Ry. Co, and Atchison, Topeka and Santa Fe Ry. Co, before the Interstate Commerce Commission, Docket No. 39002, December 16. 1983, on Behalf of Utility Fuels, Inc.
18 "In the Matter of the Petition of the State of Michigan Concerning the Effects of Certain Federal Decisions on Local Telephone Service," before the Federal Communications Commission, CC Docket No.83-788, September 26, 1983 "In the Matter of Coal Rate Guidelines -- Nationwide, ExParte No. 347 (Sub No. 1)," before the Interstate Commerce Commission, July 28, 1983 "Federal Energy Conservation Programs," before the United States Environmental Protection Agency, July 14, 1981 "Building Energy Performance Standards," before the Department of Energy, March 27, 1980 "Comment on the Incremental Pricing Provisions of the Natural Gas Policy Act," before the Federal Energy Regulatory Commission, Docket No.
RM 80-10 FEDERAL CONGRESSIONAL Testimony Of Dr. Mark Cooper On Competition In The Evolving Digital Marketplace, Subcommittee On Courts And Competition Policy, Committee On The Judiciary, U.S. House Of Representatives, September 16, 2010 Testimony of Dr. Mark Cooper on Is There Life After Trinkoand Credit Suisse?
The Role of Antitrust in Regulated Industries, Subcommittee on Courts and Competition Policy Committee on the Judiciary, U.S. House of Representatives, June 15, 2010 Testimony of Dr. Mark Cooper, Senior Fellow for Economic Analysis Institute for Energy and the Environment, Vermont Law School, on Economic Advisability of Increasing Loan Guarantees for the Construction of Nuclear Power Plants, Domestic Policy Subcommittee, Committee on Oversight and Government Reform, U.S. House of Representatives, April 20, 2010 Testimony of Dr. Mark Cooper, on behalf of Consumer Federation of America, Free Press Consumers Union before the Commerce Committee, U.S. Senate regarding Consumers, Competition and Consolidation in the Video Broadband Market, March 11, 2010 Dr. Mark Cooper on behalf of Consumer Federation of America, Free Press, Consumers Union before the, U.S. House of Representatives, Committee on the Judiciary, Subcommittee on Antitrust, Competition Policy and Consumer Rights Regarding Competition in the Media and Entertainment Distribution Market, February 25, 2010 Dr. Mark Cooper, on behalf of Consumer Federation of America, Free Press, Consumers Union before the U.S. House of Representatives, Subcommittee on Communications, Technology, and the Internet of the Committee on Energy and Commerce regarding An Examination of the Proposed Combination of Comcast and NBC Universal, February 4, 2010 Dr. Mark Cooper, on behalf of Consumer Federation of America, Free Press, Consumers Union before the Senate Subcommittee on Antitrust, Competition Policy and Consumer Rights Judiciary Committee on The Comcast /NBC Universal Merger: What Does the Future Hold for Competition and Consumers?, February 4, 2010 Testimony of Dr. Mark Cooper Too Big to Fail? The Role of Antitrust Law in Government-Funded Consolidation in the Banking Industry, Subcommittee on Courts and Competition Policy, Committee on the Judiciary, United States House of Representatives, March 17, 2009 Excessive Speculation In Energy Commodities, Agriculture Committee, United States House of Representatives, July 10, 2008 Oversight of Energy Markets and Oil Futures Contract, Joint Hearing of the Senate Appropriations Subcommittee on Financial Services and General Government and The and the Committee on Agriculture, Nutrition and Forestry United States Senate, June 17, 2008 Energy Market Manipulation and Federal Enforcement Regimes, Committee On Commerce, Science And Transportation, United States Senate, June 3, 2008 The Financial State of the Airline Industry and the Potential Impact of a Delta/Northwest Merger, Senate Committee on Commerce Science and Transportation, Aviation Subcommittee, May 7, 2008 Consumer Effects of Retail Gas Prices, before the Judiciary Committee Antitrust Task Force, United States House of Representatives, May 7, 2008 Pumping up Prices: The Strategic Petroleum Reserve and Record Gas Prices, Select Subcommittee on Energy Independence and Global Warming, United States House of Representative, April 24, 2008 Federal Trade Commission Reauthorization, Senate Energy and Commerce Committee, September 12, 2007 Prices at the Pump: Market Failure and the Oil Industry, House Judiciary Committee, May 16, 2007 Competition and the Future of Digital Music, House Judiciary Committee, Antitrust Task Force, February 28, 2007 The State of the Airline Industry: The Potential Impact of Airline Mergers and Industry Consolidation, Senate Committee on Commerce, Science and Technology, January 24, 2007 Vertically Integrated Sports Networks and Cable Companies, Senate Judiciary Committee, December 7, 2006 Universal Service, House Committee on Energy and Commerce, June 21, 2006 Price Gouging, Senate Committee on Commerce, Science and Transportation, May 23, 2006 Gasoline: Supply, Price and Specifications, House Committee on Energy and Commerce, May 10, 2006 Competition and Convergence, Senate Committee on Commerce, Science and Transportation, March 30. 2006 Antitrust Should Promote Competition on Top of Well Regulated Infrastructure Platforms, Antitrust Modernization Commission, December 5, 2005 Video Competition in 2005 - More Competition or New Choices for Consumers, Subcommittee on Antitrust, Competition Policy and Consumer Rights, United States Senate, October 19, 2005
19 An Oversight Hearing on Record High Gasoline Prices and Windfall Oil Company Profits, Senate Democratic Policy Committee, September 19, 2005 Hurricane Katrinas Effect on Gasoline Supply and Prices, Committee on Energy and Commerce, U.S. House of Representative, September 7, 2005 The Merger Tsunami is Drowning Competition in the Communications Marketplace, House Energy and Commerce Committee, March 2, 2005 Testimony of Dr. Mark Cooper on Behalf of the Consumer Federation of America on The Digital Transition - What Can We Learn from Berlin, The Licensed-Gatekeeper Model of Spectrum Management is Kaput, Subcommittee on Telecommunications and the Internet, Committee on Energy and Commerce, U.S. House of Representatives, July 21, 2004.
Testimony of Mark Cooper on behalf or The Consumer Federation of America and Consumers Union on the Status of the U.S. Refining Industry, Subcommittee on Energy and Air Quality, Committee on Energy, U.S. House of Representatives, July 15, 2004 Testimony of Dr. Mark N. Cooper on Behalf of the consumer Federation of American and Consumers Union on Environment Regulation in Oil Refining, Environment and Public Works Committee, May 12, 2004 Testimony Of Dr. Mark Cooper, On Behalf Of Consumer Federation Of America And Consumers Union On Crude Oil: The Source Of Higher Prices? Before TheSenate Judiciary Committee, Antitrust, Competition Policy And Consumer Rights Subcommittee, April 7, 2004 Testimony of Mark Cooper on Cable Market Power in Multichannel Video Program Distribution, Subcommittee on Antitrust, Senate Judiciary Committee, February 11, 2004 Testimony Of Dr. Mark Cooper, Director Of Research On Gasoline Price Volatility, Senate Commerce Committee, October 9, 2003 Testimony Of Dr. Mark N. Cooper Director Of Research On Media Ownership, Before The Senate Commerce Committee, Washington, D. C.,
October 2, 2003 Statement of Dr. Mark Cooper on Behalf of the Consumer Federation of America and Consumers Union on The Federal Response to the 2003 Blackout: Time to Put the Public Interest First, Subcommittee on Oversight of Government Management, The Federal Workforce and the District of Columbia, Committee on Government Affairs, United States Senate, September 10, 2003 From Cheap Seats To Expensive Products, Anticompetitive Practices From The Old Economy Can Rob Consumers Of The Benefits Of The Internet Statement of Dr. Mark Cooper on behalf of The Consumer Federation Of America, before The Subcommittee On Commerce, Trade And Consumer Protection, July 18, 2002 The Financial Status of the Airline Industry, Committee on Commerce, Science and Transportation, United States Senate, September 20, 2001 Statement Of Dr. Mark Cooper on Electricity Markets: California, Subcommittee On Energy And Air Quality House Energy And Commerce Committees Subcommittee, March 22, 2001 Statement of Dr. Mark N. Cooper on Mergers Between Major Airlines: The Anti-Competitive And Anti-Consumer Effects Of The Creation Of A Private Cartel, Subcommittee On Commerce, Trade And Consumer Protection Committee On Energy And Commerce United States House of Representatives, March 21, 2001 Statement Of Dr. Mark N. Cooper On The Aviation Competition Restoration Act, Committee On Commerce, Science And Transportation, United States Senate March 13, 2001 Statement Of Dr. Mark Cooper on Digital Television, Senate Commerce Committee, March 1, 2001 The Proposed United Airlines-US Airways Merger, Antitrust Committee, United States Senate, June 14, 2000 Testimony of Dr. Mark N. Cooper on behalf of the Consumer Federation of America and Consumers Union, Electricity Restructuring at the Federal Level, Subcommittee on Energy and Power, U.S. House of Representatives, October 6, 1999 Testimony of Dr. Mark N. Cooper on Electricity Competition: Consumer Protection Issues, before the Subcommittee on Energy and Power, Energy and Commerce Committee, United States House of Representatives, May 26, 1999 Testimony of Dr. Mark N. Cooper on The Regulation of Public Utility Holding Companies, Committee on Banking, Housing, and Urban Affairs, United States Senate, April 29, 1997 "Testimony of Dr. Mark N. Cooper on Behalf of the Consumer Federation of America and the Environmental Action Foundation on Exempting Registered Holding Companies from the Public Utility Holding Company Act for Diversification into Telecommunications,"
Committee on Energy and Commerce, United States House of Representatives, July 29, 1994 "Testimony of Dr. Mark N. Cooper on Universal Service and Local Competition and S. 1822," before the Commerce Committee, United States Senate, May 17, 1994 "Testimony of Dr. Mark N. Cooper Director of Research of the Consumer Federation of America on H.R. 3636, The National Communications Competition and Information Infrastructure Act of 1993, and H.R. 3626, The Antitrust Reform Act of 1993 and the Communications Reform Act of 1993" before the Subcommittee on Telecommunications and Finance, Committee on Energy and Commerce, United States House of Representatives, February 3, 1994 "Testimony of Dr. Mark N. Cooper on Major Mergers in the Telecommunications Industry," Subcommittee on Antitrust, Monopolies and Business Rights, November 16, 1993 "Testimony of Dr. Mark N. Cooper on Physician Ownership and Referral Arrangements," before the Subcommittee on Oversight, Committee on Ways and Means, October 17, 1991 "Testimony of Dr. Mark N. Cooper on Airline Competition and Consumer Protection," Subcommittee on Aviation, Committee on Public Works and Transportation, U. S. House of Representatives, May 22, 1991 "Testimony of Dr. Mark N. Cooper on Regulatory Reform in the Electric Utility Industry," Subcommittee on Energy and Power Energy and Commerce Committee, United States House of Representatives, May 2, 1991 "Testimony of Dr. Mark N. Cooper on Telephone Consumer Privacy and Advertising Rights," Subcommittee on Telecommunications and Finance, Energy and Commerce Committee, United States House of Representatives, April 24, 1991
20 "Testimony of Dr. Mark N. Cooper on Regulatory Reform in the Electric Utility Industry," before the Committee on Energy and Natural Resources, U.S. Senate, March 14, 1991 "Testimony of Mark Cooper and Scott Hempling on Electric Utility Policies of the Federal Energy Regulatory Commission," before the Subcommittee on Environment, Energy and Natural Resources of the Government Operations Committee, U.S. House of Representatives, October 11, 1990 "Testimony of Dr. Mark N. Cooper on Caller Identification," before the Subcommittee on Technology and the Law, Judiciary Committee, U.S.
Senate, August 1, 1990 "Testimony of Dr. Mark N. Cooper on Airport Gross Receipts Fees," before the Subcommittee on Economic and Commercial Law, Judiciary Committee, U.S. House of Representatives, June 28, 1990 "Testimony of Dr. Mark N. Cooper on Airport Gross Receipts Fees," before the Subcommittee on Antitrust, Monopolies and Business Rights, Judiciary Committee, U.S. Senate, April 24, 1990 "Testimony of Dr. Mark N. Cooper on Independent Power Producers and the Public Utility Holding Company Act of 1935" Subcommittee on Energy and Power, Committee on Energy and Commerce, United States House of Representatives, September 14, 1989 "Testimony of Dr. Mark N. Cooper on Acid Rain Legislation, Subcommittee on Energy and Power, Committee on Energy and Commerce, United States House of Representatives, September 7, 1989 "Testimony of Gene Kimmelman and Dr. Mark N. Cooper on Competitive Issues in the Cable Television Industry, before the Subcommittee on Antitrust, Monopolies and Business Rights, Judiciary Committee, United States Senate, April 12, 1989 "Testimony of Peggy Miller and Dr. Mark N. Cooper, on the Savings and Loan Crisis," before the Ways and Means Committee, United States House of Representatives, March 9, 1989 "Testimony of Dr. Mark N. Cooper on The Ethics in Patient Referrals Act of 1989 and Physician Self-Referral," before the subcommittee on Health, Committee on Ways and Means, United States House of Representatives, March 2, 1989 "Joint Testimony of the Consumer Federation of American and the Citizen Labor Energy Coalition on Bypass of Natural Gas Local Distribution Companies," before the Subcommittee on Energy Regulation and Conservation, Committee, on Energy and Natural Resources, United States House of Representatives, September 29, 1988 "Independent Power Producers and the Public Utility Holding Company Act of 1935, Subcommittee on Energy and Power of the Energy and Commerce Committee, U.S. House of Representatives, September 14, 1988 "Physician Self-Dealing and Quality Control in Clinical Laboratory Testing," Energy and Commerce Committee, U.S. House of Representatives, July 6, 1988 "Joint Testimony of the Consumer Federation of American and the Citizen Labor Energy Coalition on Bypass of Natural Gas Local Distribution Companies," before the Subcommittee on Energy and Power, Energy and Commerce Committee, United States House of Representatives, May 25, 1988 "Administrative Modifications in the Implementation of the Public Utility Regulatory Act of 1978," before the Committee on Energy and Natural Resources, U.S. Senate, February 2, 1988 "Excess Deferred Taxes," before the Subcommittee on Select Revenue Measures, Ways and Means Committee, U.S. House of Representatives, December 14, 1987 "Electric Utility Regulation," Testimony before the Subcommittee on Energy and Power of the Energy and Commerce Committee, U.S. House of Representatives, September 23, 1987 "Bank Sale of Insurance," Banking Committee, U.S. Senate, July 30, 1987 "Consumer Impacts of Airline Bankruptcies," before the Subcommittee on Aviation, Committee on Public Works and Transportation, U.S. House of Representatives, June 10, 1987 "Oversight of the Rail Industry and the Staggers Act," before the Subcommittee on Surface Transportation, Committee on Commerce, Science and Transportation, June 9, 1987 "Oil Industry Taxes," before the Committee on Finance, U.S. Senate, June 5, 1987 "Comprehensive Natural Gas Legislation," before the Subcommittee on Regulation, Committee on Energy and Natural Resources, U.S. Senate, May 20, 1987 "Federal Policy Toward the Insurance Industry," before the Judiciary Committee, February 18, 1987.
"Railroad Antimonopoly Act of 1986," before the Subcommittee on Commerce, Transportation and Tourism of the Energy and Commerce Committee, U.S. House of Representatives, June 5, 1986 "Comprehensive Natural Gas Legislation," before the Subcommittee on Regulation, Energy and Natural Resources Committee, U.S. Senate, May 20, 1986 "Electric Utility Regulation," before the Subcommittee on Energy Conservation and Power, Energy and Commerce Committee, U.S. House of Representatives, March 20, 1986 "Oil Import Fees," Committee on Energy and Natural Resources, U.S. Senate, March 20, 1986 "Implementation of Staggers Rail Act or 1980," Subcommittee on Commerce, Transportation and Tourism, Energy and Commerce Committee, U.S. House of Representatives, March 13, 1986 "Implementation of the Staggers Rail Act of 1980," before the Subcommittee on Surface Transportation of the Committee on Commerce, Science and Transportation, U.S. Senate, November 4, 1985 "Recent Developments in the Natural Gas Industry," before the Subcommittee on Energy Regulation and Conservation of the Energy and Natural Resource Committee, U.S. Senate, July 11, 1985
21 "The Consumer Impact of the Proposed Norfolk Southern/Conrail Merger," before the Subcommittee on Commerce, Transportation and Tourism of the Energy and Commerce Committee, U.S. House of Representatives, July 10, 1985 "The Consumer Impact of the Unregulated Railroad Monopoly in Coal Transportation," before the Subcommittee on Monopolies and Commercial Law of the Judiciary Committee, U.S. House of Representatives, June 27, 1975 "The World Energy Outlook," before the Subcommittee on Environment, Energy and Natural Resources of the Government Operations Committee, United States House of Representatives, April 1, 1985 "Phantom Tax Reform," before the Subcommittee on Energy Conservation and Power of the Committee on Energy and Commerce, U.S. House of Representatives, June 12, 1984 "Legislative Proposals Governing Construction Work In Progress," before the Subcommittee on Energy Regulation of the Energy and Natural Resources Committee, United States Senate, April 12, 1984 "Legislation Affecting Oil Company Mergers," before the Subcommittee on Energy and Mineral Resources of the Committee on Energy and Natural Resources, United States Senate, April 10, 1984 "Legislative Proposals Governing Corporate Mergers and Takeovers," before the Subcommittee on Monopolies and Commercial Law of the Committee on Judiciary, United States House of Representatives, March 23, 1984 "Review of Federal Policies Affecting Energy Conservation and Housing," before the Subcommittee on Housing and Community Development of the Committee on Banking, Finance and Urban Affairs, United States House of Representatives, March 21, 1984 "The Staggers Rail Act of 1980," before the Subcommittee on Commerce, Transportation and Tourism of the Committee on Energy and Commerce, United States House of Representatives, July 27, 1983 "Oversight Hearings on the Staggers Rail Act of 1980," before the Subcommittee on Surface Transportation of the Committee on Commerce, Science and Transportation, United States Senate, July 26-27, 1983 "The Export of Alaskan Crude Oil," before the Subcommittee on East Asian and Pacific Affairs of the Committee on Foreign Relations, United States Senate, July 19, 1984 "Economics of Natural Gas Deregulation," before the Joint Economic Committee, United States Congress, April 15, 1983 "Bills to Amend the Export Administration Act," before the Subcommittee on International Finance and Monetary Policy of the Committee on Banking, Housing and Urban Affairs, United States Senate, April 14, 1983 "Reauthorization of the Export Administration Act," before the Subcommittee on International Economic Policy and Trade of the Committee on Foreign Affairs, United States House of Representatives, April 12, 1983 "Pending Natural Gas Legislation," before the Subcommittee on Fossil and Synthetic Fuels of the Committee on Energy and Commerce, United States House of Representatives, March 22, 1983 "Energy Conservation and Jobs," before the Subcommittee on Energy Conservation and Power of the Committee on Energy and Commerce, United States House of Representatives, March 15, 1983 "Natural Gas Hearings," before the Committee on Energy and Natural Resources, United States Senate, March 10, 1983 "The Impacts of Various Energy Tax Options," before the Subcommittee on Fossil and Synthetic Fuels of the Committee on Energy and Commerce, June 15, 1982 "Various Energy Tax Options," before the Subcommittee on Energy and Agricultural Taxation of the Committee on Finance, United States Senate, June 9, 1982 "Natural Gas Policy and Regulatory Issues," before the Committee on Energy and Natural Resources, United States Senate, March 23, 1982 "The Economic Implications of Natural Gas Deregulation," before the Subcommittee on International Trade, Finance and Security Economics of the Joint Economic Committee, United States Congress, February 18, 1982 "The Implementation of Title I of the Natural Gas Policy Act of 1978," before the Committee on Energy and Natural Resources, United States Senate, November 5, 1981 "State and Local Energy Block Grants," before the Committee on Energy and Natural Resources, United States Senate, October 16, 1981 "The National Home Weatherization Act of 1981," before the Subcommittee on Energy Conservation and Supply of the Committee on Energy and Natural Resources, United States Senate, July 15, 1981 "An Alternative Energy Budget," before the Subcommittee on Energy Conservation and Power of the Energy and Commerce Committee, United States House of Representatives, February 27, 1981 "Institutional Analysis of Policy Options to Promote Energy Conservation in New Buildings," before the Subcommittee on Energy Development and Applications of the Committee on Science and Technology, United States House of Representatives, September 25, 1980 "Building Energy Performance Standards," before the Subcommittee on Energy Regulation of the Committee on Energy and Natural Resources, United States Senate, June 26, 1980 "Analysis of No. 2 Distillate Prices and Margins with Special Focus on the Department of Energy's Methodology, before the Subcommittee on Environment, Energy and Natural Resources of the Government Operations Committee, United States House of Representatives, February 12, 1980 STATE AND PROVINCE Affidavit of Mark Cooper on Behalf of Nuclear Information Resource Service, et al., In the Matter of Hudson River Sloop Clearwater, Inc.,
Goshen Green Farms, LLC, Nuclear Information And Resource Service, Indian Point Safe Energy Coalition, And Promoting Health And Sustainable Energy, Inc., Petitioners-Plaintiffs, For A Judgment Pursuant To Article 78 Of The Cplr Against-New York State Public Service Commission, Along With Kathleen Burgess In Her Official Capacity As Secretary, Audrey Zibelman, In Her Official Capacity As Chair, Patricia L. Acampora, Gregg C. Sayre, And Diane X. Burman, In Their Official Capacities As Commissioners, Respondents-Defendants, And, Constellation Energy Nuclear Group, LLC, With Subsidiaries And Affiliates Exelon Generation Company, Llc, R.E. Ginna Nuclear
22 Power Plant, LLC, Nine Mile Point Nuclear Station, LLC, Nominal Respondents-Defendants, Supreme Court Of The State Of New York County Of Albany, Index No. 07242-16).
Direct Testimony of Dr. Mark Cooper on Behalf of Friends of the Earth and Sierra Club, Docket Nos, 2017-207-E, 2017-305-E And 2017-370-E The Economic Feasibility, Impact on Public Welfare and Financial Prospects for New Nuclear Construction, For Utah Heal, July 2013.
Testimony and Surrebuttal Testimony on Behalf Of The Sierra Club, Before The South Carolina Public Service Commission, Docket No. 2012-203-E, October 2012 Testimony of Dr. Mark Cooper on House File 9, Minnesota House of Representatives Committee on Commerce and Regulatory Reform, February 9, 2011 Direct Testimony of Dr. Mark N Cooper in Re: Nuclear Plant Cost Recovery for the Southern Alliance for Clear Energy, Before the Florida Public Service Commission, FPSC Docket No. 100009-EI, August 2010; Direct Testimony of Dr. Mark N cooper in Re: Nuclear Plant Cost Recovery for the Southern Alliance for Clear Energy, Before the Florida Public Service Commission, FPSC Docket No. 090009-EI, July 15, 2009 State Regulators, Commodity Markets, And The Collapse Of Market Fundamentalism,Joint Session of the Consumer Affairs and Gas Committees on Excessive Speculation in Natural Gas Markets: How To Safeguard Consumers, National Association of Regulatory Utility Commissioners, February 17, 2009 21st Century Policies to Achieve 21st Century Goals, prepared for Wisconsin Citizens Utility Board, Investigation into the Level of Regulation for Telecommunications Providers Updating Telecommunications Regulation in Wisconsin, PSC Docket 5-TI-1777, March 25, 2008 Comments of the Consumer Federation of America, Consumers Union, and New York Public Interest Research Group Calling for Review and Denial of the Plan for Merger, In the Matter of Joint Petition of Verizon New York Inc. and MCI for a Declaratory Ruling Disclaiming Jurisdiction Over or in the Alternative, for Approval of Agreement and Plan of Merger, Public Service Commission, State of New York, Case No. 05-C-0237, April 29, 2005 Rebuttal Testimony of Dr. Mark Cooper on Behalf of AARP, In re: Application of the National School Lunch Program and Income-Based Criterion at or Below 135% of the Federal Poverty Guidelines as Eligibility Criteria for the Lifeline and Link-up Programs, before the Florida Public Service Commission, Docket No. 040604-TL, December 17, 2004 Direct and Rebuttal Testimony Of Dr Mark N. Cooper On Behalf Of Texas Office Of Public Utility Council, Impairment Analysis Of Local Circuit Switching For The Mass Market, Public Utility Commission Of Texas, Docket No. 28607, February 9, 2004, March 19, 2004 Direct Testimony Of Dr Mark N. Cooper On Behalf Of AARP, Before The Florida Public Service Commission, Docket No. 030867-Tl, 030868-TL, Docket No. 030869-Tl, October 2, 2003 Affidavit of Dr. Mark Cooper on Behalf of the Wisconsin Citizen Utility Board, Petition of Wisconsin Bell, Inc., for a Section 271 Checklist Proceeding, before the Public Service Commission of Wisconsin, 6720-TI-170, June 10, 2002 Opposition of the Consumer Federation of America and TURN, In the Matter of the Application of Comcast Business Communications, Inc.
(U-5380-C) for Approval of the Change of Control of Comcast Business Communications, Inc., That Will Occur Indirectly as a Result of the Placement of AT&T Broadband and Comcast Corporation Under a New Parent, AT&T Comcast Corporation, In the Matter of the Application of AT&T Broadband Phone of California, LLC (U-5698-C) for Approval of the Change of Control of AT&T Broadband Phone of California, LLC That Will Occur Indirectly as a Result of the Placement of AT&T Broadband and Comcast Corporation Under a New Parent, AT&T Comcast Corporation, Public Utilities Commission Of The State Of California, Application 02-05-010 02-05-011, June 7, 2002 Protecting the Public Interest Against Monopoly Abuse by Cable Companies: Strategies for Local Franchising Authorities in the AT&T Comcast License Transfer Process, Statement to the City of Boston, May 14, 2002 Prefiled Testimony Of Dr. Mark N. Cooper On Behalf Of The Virginia Citizen Consumers Council, In The Matter Of Application Of Virginia Electric And Power Company For Approval Of A Functional Separation Plan, Virginia State Corporation Commission, Case No.
Pue000584, August 24, 2001 Direct Testimony Of Dr. Mark N. Cooper On Behalf Of The Attorney General Of Oklahoma, Before The Oklahoma Corporation Commission Application Of Ernest G. Johnson, Director Of The Public Utility Division, Oklahoma Corporation Commission, To Require Public Service Company of Oklahoma To Inform The Commission Regarding Planning Of Energy Procurement Practices And Risk Management Strategies And For A Determination As To Appropriate Methods To Lessen The Impact Of Energy Price Volatility Upon Consumers, Cause No. Pud 2001-00096, May 18, 2001 Direct Testimony Of Dr. Mark N. Cooper On Behalf Of The Attorney General Of Oklahoma, Before The Oklahoma Corporation Commission Application Of Ernest G. Johnson, Director Of The Public Utility Division, Oklahoma Corporation Commission, To Require Oklahoma Gas and Electric Company To Inform The Commission Regarding Planning Of Energy Procurement Practices And Risk Management Strategies And For A Determination As To Appropriate Methods To Lessen The Impact Of Energy Price Volatility Upon Consumers, Cause No. Pud 2001-00095, May 18, 2001 Direct Testimony Of Dr. Mark N. Cooper On Behalf Of The Attorney General Of Oklahoma, Before The Oklahoma Corporation Commission Application Of Ernest G. Johnson, Director Of The Public Utility Division, Oklahoma Corporation Commission, To Require Arkla, A Division of Reliant Energy Resources Corporation To Inform The Commission Regarding Planning Of Energy Procurement Practices And Risk Management Strategies And For A Determination As To Appropriate Methods To Lessen The Impact Of Energy Price Volatility Upon Consumers, Cause No. Pud 2001-00094, May 18, 2001 Direct Testimony Of Dr. Mark N. Cooper On Behalf Of The Attorney General Of Oklahoma, Before The Oklahoma Corporation Commission Application Of Ernest G. Johnson, Director Of The Public Utility Division, Oklahoma Corporation Commission, To Require Oklahoma Natural Gas Company To Inform The Commission Regarding Planning Of Energy Procurement Practices And Risk Management Strategies And For A Determination As To Appropriate Methods To Lessen The Impact Of Energy Price Volatility Upon Consumers, Cause No. Pud 2001-00097, May 14, 2001
23 Affidavit Of Mark N. Cooper On Behalf Of The Office Of Consumer Advocate, Before The Pennsylvania Public Utility Commission, Consultative Report On Application Of Verizon Pennsylvania Inc., For FCC Authorization To Provide In-Region Interlata Service In Pennsylvania Docket M-00001435, February 10, 2001 Statement of Dr. Mark N. Cooper before the Governors Task on Electricity Restructuring, Las Vegas Nevada, November 30, 2000 Open Access, Committee on State Affairs of the Texas House of Representatives, August 16, 2000 Prepared Statement Of Dr. Mark N. Cooper, Director Of Research Consumer Federation of America, on Internet Consumers Bill of Rights, Senate Finance Committee Annapolis, Maryland March 7, 2000 Prepared Statement Of Dr. Mark N. Cooper, Director Of Research Consumer Federation of America, on Internet Consumers Bill of Rights, House Commerce and Governmental Matter Committee Annapolis, Maryland February 29, 2000 Comments Of The Consumer Federation Of America On The Report Of The Expert Review Panel, To The Budget And Fiscal Management Committee, Metropolitan King County Council, October 25, 1999 Testimony Of Dr. Mark N. Cooper On Behalf Of AARP, In The Matter Of The Commission Ordered Investigation Of Ameritech Ohio Relative To Its Compliance With Certain Provisions Of The Minimum Telephone Service Standards Set Forth In Chapter 4901:1-5, Ohio Administrative Code, October 20, 1999 Testimony of Dr. Mark N. Cooper on behalf of Residential Customers, In the Matter of the Investigation on the Commissions Own Motion Into all Matters Relating to the Merger of Ameritech Corporation and SBC Communications Inc. before the Indiana Utility Regulatory Commission in Cause NO. 41255, June 22, 1999 Testimony of Dr. Mark N. Cooper, on behalf of the Pennsylvania Office of Consumer Advocate, before the Pennsylvania Public Utility Commission, In the Matter of the Joint Petition for Global Resolution of Telecommunications Proceedings, Docket Nos. P-00991649, P-oo981648, June 1999 Direct Testimony of Dr. Mark N. Cooper on Behalf of the Pennsylvania Office of Consumer Advocate, before the Pennsylvania Public Utility Commission, In the Matter of the Acquisition of GTE by Bell Atlantic, Docket Nos. A-310200F0002, A-311350F0002, A-310222F0002, A-310291F0003, March 23, 1999 Testimony of Dr. Mark N. Cooper on Behalf of AARP, In the Matter of the SBC Ameritech Merger, Before The Public Utilities Commission Of Ohio, Case No. 99-938-TP-COI, December 1998 Preserving Just, Reasonable and Affordable Basic Service Rates, on behalf of the American Association of Retired Persons, before the Florida Public Service Commission, Undocketed Special Project, 980000A-SP, November 13, 1998.
Telecommunications Service Providers Should Fund Universal Service, Joint Meeting Communications Committee and Ad Hoc Committee on Consumer Affairs, NARUC 110th Annual Convention, November 8, 1998 Testimony of Dr. Mark N. Cooper on behalf of AARP, In the Matter of the Joint Application for Approval of Reorganization of Illinois Bell Telephone Company d/b/a Ameritech Illinois and Ameritech Illinois Metro, Inc. Into SBC Communications Inc., in Accordance with Section 7-204 of the Public Utility Act, Illinois Commerce Commission, Docket NO.98-055, October 1998 Testimony and Supplemental Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General, before the Department of Public Utilities, State of Connecticut, Joint Application of SBC Communications Inc. and Southern New England Telecommunications Corporation for Approval of Change of Control, Docket No. 9802-20, May 7, 1998.
Affidavit of Mark N. Cooper on Behalf of the Consumer Federation of America, before the Public Utilities Commission of the State of California, Rulemaking on the Commissions Own Motion to Govern Open Access to Bottleneck Services and Establish a Framework for Network Architecture Development of Dominant Carrier Networks, Investigation on the Commissions Own Motion Into Open Access and Network Architecture Development of Dominant Carrier Networks, Order Instituting Rulemaking on the Commissions Own Motion Into Competition for Local Exchange Service, Order Instituting, R. 93-04-003, I.93-04-002, R. 95-04-043, R.85-04-044.
June 1998.
Stonewalling Local Competition, Consumer Federation of America, and Testimony of Dr. Mark N. Cooper on behalf of Citizen Action before the Board of Public Utilities, In the Matter of the Boards Investigation Regarding the Status of Local Exchange Competition in New Jersey (Docket No. TX98010010), March 23, 1998.
Direct Testimony of Mark Cooper on Behalf of Residential Consumers, In the matter of the Investigation on the Commissions own motion into any and all matters relating to access charge reform including, but not limited to high cost or Universal Service funding mechanisms relative to telephone and telecommunications services within the state of Indiana pursuant to IC-8-1-2-51, 58, 59, 69; 8-1-2.6 Et Sec., and other related state statues, as well as the Federal Telecommunications Act of 1996 (47 U.S.C.) Sec. 151, Et. Sec.,
before the Indiana Utility Regulatory Commission, April 14, 1998 Affidavit of Mark N. Cooper on Behalf of the Texas Office of Public Utility Counsel, In the matter of Application of SBC. Communications Inc., Southwestern Bell Telephone Company Service Inc., d/b/a Southwestern Bell Long Distance, for Provision of In-Region InterLATA Service Texas, Public Utility Commission of Texas, Project 16251, April 1, 1998 Comments of The Consumer Federation of America, Re: Case 97-021 - In the Matter of Petition of New York Telephone Company for approve of its statement of generally accepted terms and conditions pursuant to Section 252 of the Telecommunications Act of 1996 and Draft Filing of Petition for InterLATA Entry pursuant to Section 271 of the Telecommunications Act of 1996, before the State of New York, Public Service Commission, March 23, 1998.
Access Charge Reform and Universal Service: A Primer on Economics, Law and Public Policy, Open Session, before the Washington Transport and Utility Commission, March 17, 1998 Responses of Dr Mark N. Cooper on behalf of the American Association of Retired persons and the Attorney General of Washington, Public Counsel Section, before the Washington Transport and Utility Commission, March 17, 1998, Direct Testimony of Dr. Mark N. Cooper on Behalf of the North Carolina Justice and Community Devilment Center, In the Matter of Establishment of Intrastate Universal Service Support Mechanisms Pursuant to G.S.62-110 (f) and Section 254 of the Telecommunications Act of 1996, before the North Carolina Utilities Commission, Docket No. P-100, SUB 133g, February 16, 1998
24 Comments of The Consumer Federation of America, Re: Case 97-021 - In the Matter of Petition of New York Telephone Company for approve of its statement of generally accepted terms and conditions pursuant to Section 252 of the Telecommunications Act of 1996 and Draft Filing of Petition for InterLATA Entry pursuant to Section 271 of the Telecommunications Act of 1996, before the State of New York, Public Service Commission, January 6, 1998.
Testimony of Dr. Mark N. Cooper on Behalf of the Arizona Consumers Council, In the Matter of the Competition in the Provision of Electric Services Throughout the State of Arizona, The Arizona Corporation Commission, January 21, 1998 Direct Testimony of Dr. Mark N. Cooper on Behalf of the Virginia Citizens Consumers Council, Virginia Electric Power Company, Application of Approval of Alternative Regulatory Plan, State Corporation Commission of Virginia, December 15, 1997 Electric Industry Restructuring: Who Wins? Who Loses? Who Cares? Hearing on Electric Utility Deregulation, National Association of Attorneys General, November 18, 1997 Direct Testimony of Dr. Mark N. Cooper in Response to the Petition of Enron Energy Services Power, Inc., for Approval of an Electric Competition and Customer Choice Plan and for Authority Pursuant to Section 2801 (E)(3) of the Public Utility Code to Service as the Provider of Last Resort in the Service Territory of PECO Energy Company on Behalf of the American Association of Retired Persons, Pennsylvania Public Utility Commission v. PECO, Docket No. R-00973953, November 7, 1997.
Policies to Promote Universal Service and Consumer Protection in the Transition to Competition in the Electric Utility Industry, Regulatory Flexibility Committee, Indiana General Assembly, September 9, 1997 Reply Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General of Arkansas, In the Matter of Rulemaking Proceeding to Establish Rules and Procedures Necessary to Implement the Arkansas Universal Service Fund, Arkansas Public Service Commission, Docket No. 97-041-R, July 21, 1997 Statement of Dr. Mark N. Cooper, In the Matter of the Rulemaking by the Oklahoma Corporation Commission to Amend and Establish Certain Rules Regarding the Oklahoma Universal Service Fund, Cause No. RM 970000022.
Direct Testimony of Dr. Mark N. Cooper on Behalf of the Alliance for South Carolinas Children, In Re: Intrastate Universal Service Fund, before the Public Service Commission of South Carolina, Docket NO. 97-239-C, July 21, 1997 Direct Testimony of Dr. Mark N. Cooper on Behalf of Kentucky Youth Advocate, Inc., In the Matter of Inquiry into Universal Service and Funding Issues, before the Public Service Commission Commonwealth of Kentucky, Administrative Case NO. 360, July 11, 1997 Direct Testimony of Dr. Mark N. Cooper on Behalf of the Office of Public Utility Counsel, Application of Southwestern Bell Telephone Company for Non-Rate Affecting Changes in General Exchange Tariff, Section 23, Pursuant to PURA95 s.3.53 (D), before the Public Utility Commission of Texas, July 10, 1997 Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons, Application of Pennsylvania Power and Light Company for Approval of its Restructuring Plan Under Section 2806 of the Public Utility Code, Pennsylvania Public Utility Commission, Docket No. R-00973954, July 2, 1997 Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons, Application of PECO Company for Approval of its Restructuring Plan Under Section 2806 of the Public Utility Code, Pennsylvania Public Utility Commission, June 20, 1997 Initial Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General of Arkansas, In the Matter of Rulemaking Proceeding to Establish Rules and Procedures Necessary to Implement the Arkansas Universal Service Fund, Arkansas Public Service Commission, Docket No. 97-041-R, June 16, 1997 A New Paradigm for Consumer Protection, National Association of Attorneys General, 1997 Spring Consumer Protection Seminar, April 18, 1997.
Statement of Dr Mark N. Cooper, Project on Industry Restructuring, Public Utility Commission of Texas, Project No. 15000, May 28, 1996 Direct Testimony of Dr. Mark N. Cooper Submitted on behalf of The American Association of Retired Persons, before the Public Service Commission, State of New York, In the Matter of Competitive Opportunities Case 94-E-0952 New York State Electric and Gas Co.
96-E-0891; Rochester Gas and Electric Corp. 96-E-0898 Consolidated Edison Company of New York, Inc. 96-E-0897 Direct Testimony of Dr. Mark N. Cooper on Behalf of Office of Consumer Advocate, before the Pennsylvania Public Utility Commission, Pennsylvania Public Utility Commission Bureau of Consumer Services v. Operator Communications, Inc. D/b/a Oncor Communications, Docket No. C-00946417, May 2, 1997 Direct Testimony of Dr. Mark N. Cooper, on Behalf of New York Citizens Utility Board, the Consumer Federation of America, the American Association of Retired Persons, Consumers Union, Mr. Mark Green, Ms. Catherine Abate, the Long Island Consumer Energy Project, before the Public Service Commission, State of New York, Proceeding on Motion of the Commission as the Rates, Charges, Rules and Regulations of New York Telephone Company, NYNEX Corporation and Bell Atlantic Corporation for a Declaratory Ruling that the Commission Lacks Jurisdiction to Investigate and Approve a Proposed Merger Between NYNEX and a Subsidiary of Bell Atlantic, or, in the Alternative, for Approval of the Merger, Case 96-c-603, November 25, 1996 Consumer Protection Under Price Cap Regulation: A Comparison of U.S. Practices and Canadian Company Proposals, before the CRTC, Price Cap Regulation and Related Matters, Telecom Public Notice CRTC, 96-8, on behalf of Federation Nationale des Associations de Consommateurs du Quebec and the National Anti-Poverty Organization, August 19, 1996 Responses of Dr. Mark N. Cooper on Behalf of the Attorney General of Oklahoma, In the Matter of the Rulemaking by the Oklahoma Corporation Commission to Establish Rules and Regulations Concerning Universal Service, Cause NO. RM 96000015, May 29, 1996 Statement of Dr. Mark N. Cooper on Behalf of the Attorney General of Oklahoma, In the Matter of the Oklahoma Corporation Commission to Establish Rules and Regulations Concerning Pay Telephones, Cause NO. RM 96000013, May 1996 Statement of Dr. Mark N. Cooper on Behalf of the Attorney General of Oklahoma, In the Matter of An Inquiry by the Oklahoma Corporation Commission into Alternative Forms of Regulation Concerning Telecommunications Service, Cause NO. RM 950000404 Statement of Dr. Mark N. Cooper to the System Benefits Workshop, Project on Industry Restructuring, Project No. 15000, before the Public Utility Commission of Texas, May 28, 1996
25 Remarks of Dr. Mark N. Cooper, Panel o n Service Quality from the Consumer Perspective, NARUC Winter Meetings, Washington, D.C.,
February 26, 1996 "Attorney General's Comments," Before the Arkansas Public Service Commission, In the Matter of the Non-Traffic Sensitive Elements of Intrastate Access Charges and Carrier Common Line and Universal Service Fund Tariffs of the Local Exchange Companies, Docket NO. 86-159-U, November 14, 1995 "Reply Comments and Proposed Rules of the Oklahoma Attorney General," Before the Corporation Commission of the State of Oklahoma, In the Matter of the Rulemaking of the Oklahoma Corporation Commission to Establish Rules and Regulations for Local Competition in the Telecommunications Market, Cause No. RM 950000019, October 25, 1995 "Remarks of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons to the Members of the Executive Committee,"
Indiana Utility Regulatory Commission, in the Matter of the Investigation on the Commission's Own Motion into Any and All Matters Relating to Local Telephone Exchange Competition Within the State of Indiana, Cause No. 39983, September 28, 1995 "Direct Testimony of Dr. Mark N. Cooper on Behalf of the Office of Public Utility Counsel," before the Public Utility Commission of Texas, Petition of MCI Telecommunications Corporation for an Investigation of the Practices of Southwestern Bell Telephone Company Regarding the 713 Numbering Plan Area and Request for a Cease and Desist Order Against Southwestern Bell Telephone Company, SOAH Docket No. 473-95-1003, September 22, 1995 "Rebuttal Testimony of Dr. Mark N. Cooper on Behalf of the Office of the Attorney General State of Arkansas," Before the Arkansas Public Service Commission, In the Matter of an Earnings Review of GTE Arkansas Incorporated, Docket NO. 94-301-U, August 29, 1995 "Direct Testimony of Dr. Mark N. Cooper on Behalf of the Office of Public Utility Counsel," before the Public Utility Commission of Texas, Petition of MCI Telecommunications Corporation for an Investigation of the Practices of Southwestern Bell Telephone Company Regarding the 214 Numbering Plan Area and Request for a Cease and Desist Order Against Southwestern Bell Telephone Company, Docket NO. 14447, August 28, 1995 "Direct Testimony of Mark N. Cooper On Behalf of the Office of the People's Counsel of the District of Columbia," Before the Public Service Commission of the District of Columbia, In the Matter of Investigation Into the Impact of the AT&T Divestiture and Decisions of the Federal Communications Commission on the Chesapeake and Potomac Telephone Company's Jurisdictional Rates, July 14, 1995 "Comments of Consumer Action and the Consumer Federation of America," Before the Public Utilities Commission of California, Order Instituting Rulemaking on the Commission's Own Motion into competition for Local Exchange Service, Docket Nos. R. 95-04-043 and I. 95-04-044, May 23, 1995 "Testimony of Dr. Mark N. Cooper on Behalf of the Arkansas Attorney General," before the Arkansas Public Service Commission, In the Matter of an Earnings Review of Southwestern Bell Telephone Company, Docket NO. 92-260-U, April 21, 1995 "Promoting Competition and Ensuring Consumer Protection on the Information Superhighway, Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons and the Consumer Federation of America on Proposed Revisions of Chapter 364,"
Committee on Commerce and Economic Opportunities, Florida Senate, April 4, 1995 "Direct Testimony and Exhibits of Dr. Mark N. cooper on Behalf of the Division of consumer Advocacy," In the Matter of Public Utilities Commission Instituting a Proceeding on Communications, Including an Investigation of the Communications Infrastructure in Hawaii, docket No. 7701, March 24, 1995 "Promoting Competition and Ensuring Consumer Protection on the Information Superhighway, Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons and the Consumer Federation of America on Proposed Revisions of Chapter 364,"
Florida House of Representative, March 22, 1995 "Prepared Testimony of Dr. Mark N. Cooper on Behalf of the Office of the Attorney General State of Arkansas," Before the Arkansas Public Service Commission, In the Matter of an Earnings Review of GTE Arkansas Incorporated, Docket NO. 94-301-U, March 17, 1995 "Statement of Dr. Mark N. Cooper," DPUC Investigation into The Southern New England Cost of Providing Service, Docket No. 94-10-01, January 31, 1995 "Statement of Dr. Mark N. Cooper," DPUC Exploration of Universal Service Policy Options, Docket No. 94-07-08, November 30, 1994 "Statement of Dr. Mark N. Cooper," DPUC Investigation of Local Service Options, including Basic Telecommunications Service Policy Issues and the Definition of Basic Telecommunications Service, Docket No. 94-07-07, November 15, 1994 "Testimony of Dr. Mark N. Cooper on Behalf of Attorney General of the Commonwealth of Kentucky, Utility and Rate Intervention Division, before the Public Service Commission, Commonwealth of Kentucky, Case No.94-121, August 29, 1994 "Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons," before the Public Utilities Commission of Ohio, In the Matter of the Application of the Ohio Bell Telephone Company for Approval of an Alternative Form of Regulation and In the Matter of the Complaint of the Office of Consumers' Counsel, v. Ohio Bell Telephone Company, Relative to the Alleged Unjust and Unreasonable Rates and Charges, Case Nos. 93-487-TP-ALT, 93-576-TP-CSS, May 5, 1994 "Reply Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General of Arkansas," before the Arkansas Public Service Commission, in the Matter of the Consideration of Expanded Calling Scopes and the Appropriate NTS Allocation and Return on Investments for the Arkansas Carrier Common Line Pool, Docket No. 93125-U, May 4, 1994 "Direct Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General of Arkansas," before the Arkansas Public Service Commission, in the Matter of the Consideration of Expanded Calling Scopes and the Appropriate NTS Allocation and Return on Investments for the Arkansas Carrier Common Line Pool, Docket No. 93125-U, April 22, 1994 "Comments of Dr. Mark N. Cooper on Behalf of Consumers Union, Southwest Regional Office, before the Public Utility Commission of Texas, Request for Comments on the Method by which Local Exchange Services are Priced, Project No. 12771, April 18, 1994 "Comments of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons, Before the Tennessee Public Service Commission, Inquiry for Telecommunications Rule making Regarding Competition in the Local Exchange, Docket No. 94-00184, March 15, 1994
26 Rebuttal Testimony of Dr. Mark N. Cooper on Behalf of the Virginia Citizens Consumer Council, Inc., before the State Corporation Commission at Richmond, Commonwealth of Virginia, In the Matter of Evaluating Investigating the Telephone Regulatory Case No.
PUC930036 Methods Pursuant to Virginia Code S56-235.5, March 15, 1994 "Testimony of Dr. Mark N. Cooper on Behalf of the Virginia Citizens Consumer Council, Inc., before the State Corporation Commission at Richmond, Commonwealth of Virginia, In the Matter of Evaluating Investigating the Telephone Regulatory Case No. PUC930036 Methods Pursuant to Virginia Code S56-235.5, February 8, 1994 "Testimony of Dr. Mark N. Cooper on Behalf of The American Association of Retired Persons, Citizen Action Coalition, Indiana Retired Teachers Association, and United Senior Action, before the Indiana Utility Regulatory Commission, Cause No. 39705, December 17, 1993 "Testimony of Dr. Mark N. Cooper on Behalf of the Virginia Citizens Consumer Council, Inc.," before the State Corporation Commission at Richmond, Commonwealth of Virginia, In the Matter of Evaluating the Experimental Plan for Alternative Regulation of Virginia Telephone Companies, Case No. PUC920029, October 22, 1993 "Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General," before the Arkansas Public Service Commission, In the Matter of An Earnings Review of Southwestern Bell Telephone Company, Docket No. 92-260-U, 93-114-C, August 5, 1993 "Rebuttal Testimony of Dr. Mark N. Cooper on Behalf of the Attorney General," before the Public Service Commission of the State of Missouri, The Staff of the Missouri Public Service Commission vs. Southwestern Bell Telephone and Telegraph Company, Case No. TO 192, April 30, 1993 "Direct Testimony of Dr. Mark N. Cooper on Behalf of the Office of Consumer Counsel," before the Public Utilities Commission of the State of Colorado, In the Matter of the Investigatory Docket Concerning Integrated Service Digital Network, Docket No. 92I-592T "Direct Testimony of Dr. Mark N. Cooper on Behalf of the People's Counsel," before the Florida Public Service Commission, Comprehensive Review of the Revenue Requirement and Rate Stabilization Plan of Southern Bell Telephone and Telegraph Company, Docket No.
900960-TL, November 16, 1992 "Direct Testimony of Dr. Mark N. Cooper on Behalf of the American Association of Retired Persons," before the Florida Public Service Commission, Comprehensive Review of the Revenue Requirement and Rate Stabilization Plan of Southern Bell Telephone and Telegraph Company, Docket No. 900960-TL, November 16, 1992 "Testimony of Dr. Mark N. Cooper" before the Regulatory Flexibility Committee, General Assembly, State of Indiana, August 17, 1992 "Testimony of Dr. Mark N. Cooper On Behalf of the Consumer Advocate, before the Public Service Commission of South Carolina, Petition of the Consumer Advocate for the State of South Carolina to Modify Southern Bell's Call Trace Offering, Docket No. 92-018-C, August 5, 1992 "Telecommunications Infrastructure Hoax," before the Public Service Commission of Colorado, Conference on ISDN for the Rest of Us, April 23, 1992 "Testimony of Dr. Mark N. Cooper on Behalf of the Consumer Federation of America," before the Corporation Commission of the State of Oklahoma, In the Matter of the Corporation Commission's Notice of Inquiry Regarding Telecommunications Standards in Oklahoma, Cause No. PUD 1185, February 28, 1992 "Testimony of Dr. Mark N. Cooper on Behalf of the Consumer Federation of America," before the Georgia Public Service Commission, In the Matter of A Southern Bell Telephone and Telegraph Company Cross-subsidy, Docket No. 3987-U, February 12, 1992 "Testimony of Dr. Mark N. Cooper on Behalf of the Consumer Federation of America," before the Arkansas Public Service Commission, in the Matter of an Inquiry into Alternative Rate of Return Regulation for Local Exchange Companies, Docket No. 91-204-U, February 10, 1992 "Statement on Behalf of the Consumer Federation of America on HB 1076," before the Missouri General Assembly, January 29, 1992 "Testimony on behalf of the American Association of Retired Persons and the Consumer Federation of America," before the Legislative P.C. 391 Study Committee of the Public Service Commission of Tennessee, January 13, 1992 "Direct Testimony on Behalf of the "Consumer Advocate," Public Service Commission State of South Carolina, In the Matter of the Application of Southern Bell Telephone and Telegraph Company for Approval of Revision to its General Subscribers Service Tariff (Caller ID),
Docket No. 89-638-C, December 23, 1991 "Comments of the Consumer Federation of America on Proposed Telecommunications Regulation in New Jersey (S36-17/A-5063)," New Jersey State Senate, December 10, 1991 "Comments of the Consumer Federation of America," Before the Public Service Commission, State of Maryland, In the Matter of a Generic Inquiry by the Commission Into the Plans of the Chesapeake and Potomac Telephone Company of Maryland to Modernize the Telecommunications Infrastructure, Case No. 8388, November 7, 1991 "On Behalf of the Office of Consumers Counsel," before the Public Utilities Commission of Ohio, In the Matter of the Application of the Ohio Bell Telephone Company to Revise its Exchange and Network Services Tariff, P.U.C.O. No. 1, to Establish Regulations, Rates, and Charges for Advanced Customer Calling Services in Section 8. The New Feature Associated with the New Service is Caller ID, Case No. 90-467-TP-ATA; In the Matter of the Application of the Ohio Bell Telephone Company to Revise its Exchange and Network Service Tariff, P.U.C.O. No 1, to Establish Regulations, Rates and Charges for Advanced Customer Calling Services in Section 8.,
The New Feature Associated with the New Service is Automatic Callback, Case No. 90-471-TP-ATA, September 3, 1991 "On Behalf of the American Association of Retired Persons," Before the Senate Select Telecommunications Infrastructure and Technology Committee, 119th Ohio General Assembly, July 3, 1991 "On Behalf of the Cook County State's Attorney," before the Illinois Commerce Commission, In Re: Proposed Establishment of a Custom Calling Service Referred to as Caller ID and Related Custom Service, Docket Nos. 90-0465 and 90-0466, March 29, 1991 "On Behalf of the Vermont Public Interest Research Group," before the Public Service BoardIn Re: Investigation of New England Telephone and Telegraph Company's Phonesmart Call Management Services, Docket No. 54-04, December 13, 1990
27 "On Behalf of the Office of Consumer Advocate," before the State of Iowa, Department of Commerce, Utilities Division, In Re: Caller ID and Related Custom Service, Docket No. INU-90-2, December 3, 1990 "On Behalf of the Office of Public Counsel," before the Florida Public Service Commission, In Re: Proposed Tariff Filings by Southern Bell Telephone and Telegraph Company When a Nonpublished Number Can be Disclosed and Introducing Caller ID to Touchstar Service, Docket No. 891194-TI, September 26, 1990 "On Behalf of the Office of Public Advocate," before the Public Service Commission, State of Delaware, In the Matter of: The Application of the Diamond State Telephone Company for Approval of Rules and Rates for a New Service Known as Caller*ID, PSC Docket No. 90-6T, September 17, 1990 "On Behalf of the Maryland People's Counsel," before The Public Service Commission of Maryland, In the Matter of Provision of Caller Identification Service by the Chesapeake and Potomac Company of Maryland, Case No. 8283, August 31, 1990 "On Behalf of the Office of Attorney General," before the Commonwealth of Kentucky, Public Service Commission, In the Matter of the Tariff Filing of GTE South Incorporated to Establish Custom Local Area Signaling Service, Case No.90-096, August 14, 1990 "On Behalf of the Consumers' Utility Counsel," before the Georgia Public Service Commission Re: Southern Bell Telephone Company's Proposed Tariff Revisions for Authority to Introduce Caller ID, Docket No. 3924-U, May 7, 1990 "Testimony of Dr. Mark N. Cooper on Caller Identification" before the Committee on Constitutional and Administrative Law, House of Delegates, Annapolis, Maryland, February 22, 1990 "On Behalf of the Office of People's Counsel of the District of Columbia," before the Public Service Commission of the District of Columbia in the Matter of the Application of the Chesapeake and Potomac Telephone Company to Offer Return Call and Caller ID within the District of Columbia, Case No. 891, February 9, 1990 "On Behalf of the Office of Consumer Advocate" before the Pennsylvania Public Utility Commission in the Matter of Pennsylvania Public Utility Commission v. The Bell Telephone Company of Pennsylvania, Docket NO. R-891200, May 1989.
"Statement of Dr. Mark N. Cooper, Joint Hearing on the Public Utility Holding Company Act of 1935," Committees on Finance and Technology and Electricity, National Association of Regulatory Utility Commissioners, February 28, 1989 "On Behalf of Manitoba Anti-poverty Organization, the Manitoba Society of Seniors and the Consumers Association of Canada (Manitoba)"
before the Public Utilities Board in the Matter of the Request of Manitoba Telephone System for a General Rate Review, February 16, 1989 "On Behalf of the Ohio Consumers Counsel, In the Matter of the Application of GTE MTO Inc. for Authority to Increase and Adjust its Rates and Charges and to Change Regulations and Practices Affecting the Same, Case No. 87-1307-TP-Air," before the Public Utility Commission of Ohio, May 8, 1988 "On Behalf of the Evelyn Soloman, Proceeding on Motion of the Commission as to the Rates, Charges and Regulations of Niagara Mohawk Power Corporation, Case Nos. 29670 and 29671," before the State of New York Public Service Commission, February 16, 1988 "An Economic Perspective - The Status of Competition in the Telecommunications Industry and Its Impact on Taxation Policy," Before the Joint Subcommittee on the Taxation of The Telecommunications Industry, December 8, 1987 "On Behalf of the Office of Consumer Counsel, State of Washington," In the Matter of the Petition of AT&T Communications of Pacific Northwest, Inc. for Classification as a Competitive Telecommunications Company, March 24, 1987 "On Behalf of Manitoba Anti-poverty Organization and the Manitoba Society of Seniors," before the Public Utilities Board in the Matter of the Request of Manitoba Telephone System for a General Rate Review, March 16, 1987 "On Behalf of the Office of Consumers' Counsel, State of Ohio," In the Matter of the Application of the Ohio Bell Telephone Company for Authority to Amend Certain of its Intrastate Tariffs to Increase and Adjust the Rates and Charges and to Change its Regulations and Practices Affecting the Same, Case No. 84-1435-TP-AIR, April 6, 1986 On Behalf of Manitoba Anti-poverty Organization and Manitoba Society of Seniors," before the Public Utilities Board in the Matter of the Request of Manitoba Telephone System for a General Rate Review, February 6, 1986 "On Behalf of Mississippi Legal Services Coalition, in the Matter of Notice by Mississippi Power and Light of Intent to Change Rates" Before the Mississippi Public Service Commission, April 15, 1985 "On Behalf of the Universal Service Alliance, in the Matter of the Application of New York Telephone Company for Changes in it Rates, Rules, and Regulations for Telephone Service, State of New York Public Service Commission, Case No. 28961, April 1, 1985 "On Behalf of North Carolina Legal Services, in the Matter of Application of Continental Telephone Company of North Carolina for an Adjustment of its Rates and Charges, Before the North Carolina Utilities Commission, Docket No. P-128, Sub 7, February 20, 1985 "On Behalf of the Consumer Advocate in re: Application of Southern Bell Telephone and Telegraph Company for Approval Increases in Certain of Its Intrastate Rates and Charges," Before the South Carolina Public Service Commission, Docket No. 84-308-c, October 25, 1984 "On Behalf of the Office of the Consumers' Counsel in the Matter of the Commission Investigation into the Implementation of Lifeline Telephone Service by Local Exchange Companies," Before the Public Utilities Commission of Ohio, Case No. 84-734-TP-COI, September 10, 1984 "On Behalf of North Carolina Legal Services Resource Center in the Matter of Application Southern Bell Telephone and Telegraph Company for an Adjustment in its Rates and Charges Applicable to Intra-state Telephone Service in North Carolina," Before the North Carolina Utilities Commission, Docket No. P-55, Sub 834, September 4, 1984 "On Behalf of Mississippi Legal Services Coalition in the Matter of the Citation to Show Cause Why the Mississippi Power and Light Company and Middle South Energy Should not Adhere to the Representation Relied Upon by the Mississippi Public Service Commission in Determining the Need and Economic Justification for Additional Generating Capacity in the Form of A Rehearing on Certification of the Grand Gulf Nuclear Project," Before the Mississippi Public Service Commission, Docket No. U-4387, August 13, 1984
28 "On Behalf of the Mississippi Legal Services Corporation Re: Notice of Intent to Change Rates of South Central Bell Telephone Company for Its Intrastate Telephone Service in Mississippi Effective January 1, 1984," before the Mississippi Public Service Commission, Docket No. U-4415, January 24, 1984 "The Impact of Rising Energy Prices on the Low Income Population of the Nation, the South, and the Gulf Coast Region," before the Mississippi Public Service Commission, Docket No. U4224, November 1982 "In the Matter of the Joint Investigation of the Public Service Commission and the Maryland Energy Office of the Implementation by Public Utility Companies Serving Maryland Residents of the Residential Conservation Service Plan," before the Public Service Commission of the State of Maryland, October 12, 1982 "The Impact of Rising Utility Rates on he Budgets of Low Income Households in the Region of the United States Served by the Mississippi Power Company and South Central Bell Telephone Company," before the Chancery Court of Forrest County, Mississippi, October 6, 1982 "The Impact of Rising Energy Prices on the Low Income Population of the Nation, the South and the Gulf Coast Region," before the Mississippi Public Service Commission, Docket No. U-4190, August 1982
29
$0
$2,500
$5,000
$7,500
$10,000 1970 1980 1990 2000 2010 2020 2030
$2010/kw Nuclear Coal (unabated)
Coal w/ccs Onshore Wind Solar PV Utility PV Battery Equivalent Gas w/CCS Gas (Unabated)
Efficiency ATTACHMENT MNC-2 PAST, PRESENT AND FUTURE COST OF NUCLEAR POWER V. ALTERNATIVES V.C. Summer Vogtle CENTRAL Coal STATION Carbon Capture Gas Battery Eqiv.
DISTRIBUTED/
RENEWABLES Source: Updated and adapted from Mark Cooper, The Political Economy of Electricity: Progressive Capitalism and the Struggle to Build a Sustainable Sector (Santa Barbara, Praeger, 2017), Figure 2.1 and accompanying text.
(overnight cost for capital-intensive technologies, fuel-intensive technologies based on relative cost per kWh).
ATTACHMENT MNC-3 CHANGE IN U.S ELECTRICITY GENERATION (KWH) PER DOLLAR OF GDP (REAL)
Period Annual % Change Electricity/
Electricity GDP/capita GDP/capita 1950-1980
+6.4
+3.5
+2.89 1980-1995
+1.9
+2.2
-0.000
\\
1995-2015
+0.1
+1.6
-0.012 2015-2019
+0.3
+3.5
-3.1 Source: U.S. Energy Information Administration, Monthly Energy Review December 2015, http://www.eia.gov/totalenergy/data/monthly/pdf/sec7_5.pdf; US Real GDP by Year, http://www.multpl.com/us-gdp-inflation-adjusted/table.
30
$0
$40
$80
$120
$160
$200 Efficiency Utility PV Onshore Offshore Geothermal Small Modulate Large Central Coal Gas Low Carbon Nuclear Carbon Cost per MWH Low High Non-carbon Externalities Carbon @ $30/ton
$0
$40
$80
$120
$160
$200 Efficiency Utility PV Onshore Aging New Coal Gas
$/MWH Low Operating Cost Low Marginal Cost High Marginal Cost Non-Carbon Externalities Carbon @ $30/Ton ATTACHMENT MNC-4: COST OF RESOURCES Long Term Costs Per MWh Short Term Costs Per MWh Source: Lazard, Lazards Levelized Cost of Energy Analysis - Version 14.0, October 2020, Long Terms Costs are from Levelized Cost of Energy Key Assumptions. Karkour, Selim, 2020, Selim Karkour, et al., 2020, External-Cost Estimation of Electricity Generation in G20 Countries: Case Study Using a Global Life-Cycle Impact-Assessment Method, sustainability, March 5. See also, Dallas Burtraw, et. al., 2012, Power: An Inventory of Methodologies to Support Future Decision making in Comparing the Cost and Competitiveness of Electricity Generation Technologies, Resources for the Future, June, Table 1. Short term costs are from LZARD, Levelized Cost of Energy Comparison -- Renewable Energy Versus Marginal Cost of Selected Existing Conventional Generation, and Levelized cost of Energy Components - Low End, for low operating costs.
31 0
5 10 15 20 25 30 35 PERCENT 0
1 2
3 4
5 6
7 ACEEE RFF Back Rff Forward LBL Lazard PJM Mckinsey Cents per kwh Backward Looking Forward Looking Engineering ATTACHMENT MNC-5 PLENTIFUL, LOW COST EFFICIENCY TO MEET FUTURE NEEDS Efficiency Potential from Major National Studies Compared to EPA Option 1 Sources and Notes: See, ); National Research Council of the National Academies, Americas Energy Future: Technology and Transformation, Summary Edition (Washington, D.C.: 2009). The NRC relies on a study by Lawrence Berkeley Laboratory for its assessment (Richard Brown, Sam Borgeson, Jon Koomey and Peter Biermayer, U.S. Building-Sector Energy Efficiency Potential (Lawrence Berkeley National Laboratory, September 2008). McKinsey Global Energy and Material, Unlocking Energy Efficiency in the U.S. Economy (McKinsey & Company, 2009; Gold, Rachel, Laura, et. al., Energy Efficiency in the American Clean Energy and Security Act of 2009: Impact of Current Provisions and Opportunities to Enhance the Legislation, American Council for an Energy Efficient Economy, September 2009); EPA, Regulatory Impact Analysis, 2004, Table 3-11.
The Cost of Saved Electricity Source: Kenji Takahasi and David Nichols, Sustainability and Costs of Increasing Efficiency Impact: Evidence from Experience to Date, ACEEE Summer Study on Energy Efficient Buildings (Washington, D.C., 2008), p. 8-363, McKinsey Global Energy and Material, Unlocking Energy Efficiency in the U.S. Economy (McKinsey & Company, 2009); National Research Council of the National Academies, Americas Energy Future: Technology and Transformation, Summary Edition (Washington, D.C.: 2009). The NRC relies on a study by Lawrence Berkeley Laboratory for its assessment (Richard Brown, Sam Borgeson, Jon Koomey and Peter Biermayer, U.S. Building-Sector Energy Efficiency Potential (Lawrence Berkeley National Laboratory, September 2008).
32 WI NY ILL CA US FRANCE ITALY SWEDEN PORTUGAL GREECE SPAIN GERAMNY UK IRELAND DENMARK SCOTLAND 0
10 20 30 40 50 60 70 80 90 100
% of Electricity from Wind & Solar ATTACHMENT MNC-6: PERFOROMANCE ON ALTERNATIVE RESOURCES ACEEE Efficiency Scorecard 2020 NREL Wind and Solar Current Use Overall Utility Utility Achieves Potential Current Projects Rank Rank Score Savings GWh/ Use per
% of Sales Capita GWh/
million capita California 1
4 16.0 1.74 4.5
.37 6.3 New York 5
5 13.5 1.29 10.2
.55 4.2 Illinois 15 9
21.0 1.44 9.2 1.26 5.8 Average 7
6 16.8 1.49 8.0
.73 5.4 Wisconsin 26 18 7.5 0.64 6.3
.86
2.2 Sources
Berg, Weston, et al., 2020, The State Energy Efficiency Scorecard, American Council for an Energy Efficient Economy, December.Wind and Solar potential from Anthony Lopez, et al.,2012, U.S. Renewable Energy Technical Potentials: A GIS-Based Analysis NREL Technical Report NREL/TP-6A20-51946 July. Projects from, Solar and Wind Energy Research Database, visited March 22, 2021.
Penetration of Generation from Wind and Solar Energy Information Administration, Electric Supply Monthly, EMBER, EU Power Sector is 2020.
33
-$10
$10
$30
$50
$70
$90
$110
$130
$150
$/MWh Avoided Costs System Costs External Costs ATTACHMENT MNC-7: CURRENT ESTIMATES OF TOTAL SYSTEM COST Source: EIA, 2018, Levelized Cost and Levelized Avoided Cost of New Generation Resources in the Annual Energy Outlook 2018, February Tables 2 and 3, for the adjustment to levelized costs to account for the value of output, using capacity weighted averages where available and unsubsidized costs. Wiser, Ryan, Andrew Mills and Joachim Seel, 2015. Impact of Variable Renewable Energy on Bulk Power System Assets, Pricing and Costs, Argonne and Lawrence Berkeley National Laboratories, Chapter 5. Lazard, 2018. Lazards Levelized Cost of Energy Analysis
- Version 12.0 for LCOE, 10. For carbon costs, NRC, 2010, The Hidden Cost of Electricity, for non-carbon pollution costs of gas, with other resources expressed as a multiple of gas.
34 ATTACHMENT MNC-8: CREATING THE 21ST CENTURY ELECTRICITY SYSTEMS:
35 ATTACHMENT MNC - 9 : MEASURES TO MANAGE AN INTELLIGENT, DECENTRALIZED ELECTRICITY SECTOR AND REDUCE PEAK LOAD Overall Effect1 Lower Cost (including externalities, e.g., uncertainty, choice2)
Smaller Systems3 (especially the transformation dividend4)
Demand Efficiency Target efficiency to peak reduction Aggressive demand response5 Manage devices (e.g., water heater loads to reduce peak.6 Smart controllers7 Shed inflexible baseload Rates8 Target fixed-cost recovery to ramping hours Time of use rates Dispatchable storage9 Solar thermal electric with storage10 Utility storage in strategic locations11 Distributed storage Community & individual storage Air conditioning water heating with storage Electric vehicles12
36 ATTACHMENT MNC UNIVERSITY OF CHICAGO RECAP OF ENTHUSIAST/UTILITY ESTIMATES OF OVERNIGHT COST FOR NEW GW-SCALE NUCLEAR PLANTS AND SMRS Optimistic: U of Chicago Best Achievable SMR Realistic: Regulators historic nuclear learning Lazard NUSCALE High SMR 1st 30 units 2020 2030 Sources: Mark Cooper, Small modular reactors and the future of nuclear power in the United States, Energy Research & Social Science 3 (2014) 161; Rosner, Robert and Stephen Goldberg, 2011, Small Modular Reactors - Potentially Key Contributors to Future Nuclear Power Generation in the U.S., Center for Strategic and International Studies, December 1; Rosner, Robert, et al., Analysis of GW-Scale Overnight Capital Costs, EPIC, University of Chicago, Technical Paper Nov. 2011. For the cost and other problems with the only active U.S. small modular Reactor see, h. V. Ramana, 2020, Eyes Wide Shut: Problems with the Utah Associated Municipal Power Systems Proposal to Construct NuScale Small Modular Nuclear Reactors, Oregon Physicians for Social Responsibility.
37 2007 2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 ATTACHMENT MNC-11 OPERATING AND TOTAL COST OF AGING REACTORS COMPARED POINT BEACH PPA TO EFFICIENCY, WIND & UTILITY PV y =Avg. $75/MWh NY ZEC d
i s
b High Utility PV u High Efficiency S Avg. cost of alternatives Low Onshore Wind Sources: Eggers, Dan, Kevin Cole, and Matthew Davis. Nuclear... The Middle Age Dilemma? Facing Declining Performance, Higher Costs, Inevitable Mortality. Credit Suisse, 2013; Lazard. Lazards Levelized Cost of Energy Analysis12.0, November 2018, Nuclear Energy Institute, Nuclear Costs in Context, October, 2018; NEI Operating Cost (Nuclear Street News Team. NEI Lays Out the State of Nuclear Power. Nuclearstreet.com. February 26, 2014); NEI Excludes Indirect (Nuclear Energy Institute, Operating Costs, http://www.nei.org/Knowledge-Center/Nuclear-Statistics/Costs-Fuel,-
Operation,-Waste-Disposal-Life-Cycle/US-Electricity-Production-Costs-and-Components); Naureen S. Malik and Jim Poulson, New York Reactors Survival Tests Pricey Nuclear, Bloomberg, January 5, 2015, p. 2. Quad Cities is based on a $580 million subsidy (Steve Daniels, Exelon Puts an Opening Price Tag on Nuclear Rescue: $580 Million, Crains Chicago Business, September 24, 2014), converted to $25/MWH for output at risk reactors. Illinois Commerce Commission, Illinois Power Agency, Illinois Environmental Protection Agency, Illinois Department Commerce and Economic Opportunity, 2015, Response to The Illinois General Assembly Concerning House Resolution 1146, January 5, real price increase to break even, plus $11/MWH for capital. Comments of Dr.
Mark Cooper. In the Matter of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, Environmental Protection Agency, RIN 2060-AR33, November 24, 2015. Comments by Alliance For A Green Economy and Nuclear Information and Resource Service, Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, Case 15-E-0302, April 22, 2016; RE: Case 15-E-0302-In the Matter of the Implementation of a Large-Scale Renewable Program and a Clean Energy Standard Re: Case 16-E-0270: Petition of Constellation Energy Nuclear Group, LLC; R.E. Ginna Nuclear Power Plant, LLC; and Nine Mile Point Nuclear Station, LLC to Initiate a Proceeding to Establish the Facility Costs for the R.E. Ginna and Nine Mile Point Nuclear Power Plants, July 22, 2016. Energy Information Administration, Electricity Annual, 2015, Table 8.4; Point Beach Nuclear Plant Power Purchase Agreement Between FPL Energy Point Beach, LLC and Wisconsin Electric Power Company, dated as of December 19, 2006, A-1.
y = 0.0757x2 - 303.23x + 303613 R² = 0.9916 y = 0.7757x - 1532.4 R² = 0.8548 0
10 20 30 40 50 60 70 80 90 EIA Op. Ex. w/o Indirect and Capital Credit Suisse Fully Loaded Average NEI Multi Unit NEI Single Ginna w/Capital Quad Cities w/Capital Lazard New Lazard Young
Comments for NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Units 1 and 2 Docket (NRC-2020-0277)
Comments and questions from a representative of Physicians for Social Responsibility Wisconsin:
1.
I am concerned by the segmentation that is occurring in this EIS process. The division into separate parts or sections occurs in the Point Beach Nuclear Plant (PBNP) draft EIS and prevents a true comprehensive and cumulative analysis of impacts.
I will provide an example of what I mean by segmentation to explain the issue. For example, lets say an agency is conducting an EIS for a 100-mile highway and only looking at the 20 miles proposed to be constructed first and this is before it crosses a protected wetland. This is not looking at the entirety of the effects of the highway as it is known it will be longer than 20 miles. To compare to PBNP, the EIS is only looking at the 20 years of the proposed next license, not the longer-term impact of operations and existence of the plant. To reference the example, PBNPs EIS is not looking at the rest of the highway.
Then once the first 20 miles of the highway are constructed, it is easier for the agency to override the impacts on the next miles of the highway that crosses the wetland as it is economically feasible to do so or whatever reason the agency choses to get the 100-mile highway finished. This is what is happening repeatedly with Point Beach: the general EIS that is for all similar nuclear plants in the US, the EIS for the initial first license extension at PBNP and now the EIS for the proposed subsequent license extension at PBNP. It is continually putting pieces together, not a comprehensive analysis.
Segmentation is also occurring in another facet, this EIS is not looking at other factors like safety or operations, as it is conveniently diverted to other processes by the NRC and not considered in the EIS. If the EIS were to truly take a hard look at the impacts of PBNP, safety issues and their consequences, such as embrittlement, would be covered in the EIS.
Segmentation is a flaw and needs to be addressed.
2.
Relying on data from NextEra for the effects on the aquatic ecosystem from the intake and discharges of waters at Lake Michigan is inadequate. Further quantitative data needs to be used and disclosed.
3.
I request all 16 possible alternatives that were considered by the draft EIS authors to be listed, not just the 3 selected for further analysis. (Section 2.3.2) 4.
I do not understand why SMRs were chosen out of the 16 possibilities for alternatives to the proposed action. SMRs are not commercially viable.
https://www.ucsusa.org/sites/default/files/2019-10/small-isnt-always-beautiful.pdf 5.
Why was an alternative of one reactor running while the other closing not considered?
6.
I had trouble finding specifics on the deadline for the draft EIS comments. Frequently it is stated January 3, 2022, however this does not provide clarity. Are comments due by 11:59 CT on January 2, 2022, since comments are due by January 3, 2022? Or are comments due at 11:59 CT on January 3? With the timing, the NRC needs to consider time zones for the due date and time. What time zone are they using? As PBNPs physical location is in Wisconsin, it would be appropriate in Central Time, but I know NRC has used Eastern Time in the past. The public needs clarification on deadlines for public participation.
7.
In reference to refurbishment activities (2.2.2), it appears the authors are purely relying on NextEras analysis. NextEra did not identify any major refurbishment activities necessary for the continued operation of Point Beach beyond the end of the existing operating licenses (NextEra 2020b). The EIS authors should have a second source of information to verify this information. This situation happens through the EIS and NextEras information needs to be verified by additional sources of information and data.
8.
Why is the region of influence (2.3.2: 2-18) based on Wisconsin Electric Power Companys service area for energy alternatives? This forces a narrow analysis of energy alternatives.
This inherently excludes offshore wind on Lake Michigan as well as the energy produced across Wisconsin, land availability and other opportunities.
9.
It needs to be clear when the authors are relying on data from computer generated models not specific to PBNP. Even if the models are based on similarly designed nuclear reactors, there are still major differences: each reactor has likely different sourced building materials, different companies have managed each reactor and each reactor is in a different environment.
- 10. The general EIS that is used as a base EIS for all nuclear reactors needs to be updated if it is going to be used. With our advancement in technology, knowledge of environmental impacts and time for more research. The general EIS is not a sufficient analysis.
- 11. On reading 3-152, it seems that NextEra and NRC were only required to do an analysis of accidents once on a license extension application in 2004. Our knowledge of climate change related weather disasters has increased (for example look at derecho at Duane Arnold). As well, a physical structure can change in 17 years, due this timespan I dont see this analysis from 2004 as adequate.