Japan’s Path
to Sustainable
Electricity Supply
A R e view of Cu rrent Japanese Energy Policies

Bruc e C. Buc khe i t
Apr i l 2 0 1 5

SUMMARY
Following the East Japan earthquake and the nuclear incident at Fukushima, all reactors in Japan were required
to pass newly revised safety standards to confirm their continued ability to operate safely in the event of a natural
disaster and remain closed until Japanese authorities reviewed and accepted the results. As a result, nuclear
generation by electric utilities dropped from average of 30% of Japan’s total generation to 2%. The contributionof fossil-fueled generation of electricity rose to 90% of Japan’s total electricity output during 20121. Japan’s useof fossil-fueled generation was up 21% in 2012, compared to the level in 2011. Most of this increase is in the
consumption of liquefied natural gas (LNG) petroleum, with a smaller increase in the consumption of coal.

Monthly generation by electric utilities in Japan, by source(January 2007-January 2013)

fossil fuels

nuclearhydroelectric

Figure 1. Monthly generation by electric utilities in Japan, by sources. Source: EIA2

The increased use of expensive imported fossil fuels and a dramatic decline in the value of the yen has raised
prices within Japan and contributed to sustained multi-billion dollar monthly trade deficits. In April, 2014, theGovernment of Japan (GOJ) adopted the Fourth Strategic Energy Plan (SEP) that revised Japan’s approach toenergy development and use in Japan. The SEP is intended to meet Japan’s “3E+S” energy goals: Energy
Security, Economic Efficiency, Environment and Safety. Under the revised plan, coal-fired generation ofelectricity and reopening some number of idled nuclear powered electric generating units (EGUs) would be
relied on to provide baseload electric power as research and gradual introduction of renewable energy would
occur on a longer time frame. In addition, the SEP promotes additional sales of high-efficiency coal-fired EGUs
world-wide as a means of reducing global CO2 emission.

1. The remaining generation was provided by pre-existing hydropower.
2. Source: U.S. Energy Information Administration, based on Bloomberg LP.
http://www.eia.gov/todayinenergy/detail.cfm?id=10391-1-

Several months earlier, the U.S. Government had adopted a Climate Action Plan3 that disfavored thecontinued use of coal-fired generation and promoted the prompt adoption of renewable energy, with natural gas
fired Combined Cycle Gas Generation as a “bridge” fuel to a low carbon intensity future. As part of the U.S.
Climate Action Plan, the U.S. Environmental Protection Agency (USEPA) has proposed several new rules that,when finalized, will dramatically alter energy development and use in the U.S., but in a manner that is
substantially different from the most recent SEP. In January of 2014, USEPA proposed rules limiting CO2
emissions from new fossil fuel-fired power plants. Notably, the proposed limits would effectively prohibit theconstruction of new coal-fired power plants4. In June of 2014, USEPA proposed limits on existing fossil-fuelfired power plants that would force the closure of a number of existing coal-fired EGUs, require efficiency
upgrades at remaining coal-fired EGUs and promote the use of existing natural gas fired EGUs and developmentof renewable energy and energy efficiency. Final action on these proposals is scheduled for June, 2015.
Kiko Network has requested a review of the potential energy options and issues, focusing on electricity, that
may not be fully considered in the SEP and potential policy revisions for consideration within Japan. The SEP
relies on several factual assertions that are demonstrably incorrect and fails to take into account other factors thatare relevant to the consideration of Japan’s 3E+S goals. This report identifies and discusses a number of thoseincorrect assertions and overlooked issues. The SEP underestimates the potential for a rapid scale up of
renewable energy in Japan. While recognizing current problems of FIT structure and developer’s side, thecurrent backlog of certified projects waiting to commence construction still demonstrates a ready supply of RE
that can be available before the planned fleet of new coal-fired EGUs could be constructed, once the FIT isrevised realistically and transmission constraints are eliminated - for less cost than new coal-fired EGUs. The
SEP also underestimates the price volatility demonstrated over the past two decades for both coal and nuclear
fuel, fails to establish a risk premium to compensate for that volatility and fails to consider the likely increase inmaintenance costs, over and above increased safety costs, associated with continued use of older coal-fired andnuclear powered EGUs.
This report also addresses the lack of transparency concerning the operation of Japan’s energy sector andsuggests that the release of far more data concerning existing and planned EGUs than is current practice will lead
to better policy development in this critical area. Among the elements of the Climate Action Plan being
implemented in the United States is a requirement for heat rate improvements at existing fossil fuel- fired electric
generating units (EGUs). A technical review of this alternative was attempted, but could not be completed
because data needed to evaluate the potential for improving the efficiency of existing fossil fuel-fired EGUs is
not publicly available in Japan. Importantly, the SEP does not indicate that this option was even considered indeveloping the plan.

3. http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf
4. The proposed CO2 emission limit is 1000 lb/MWh (gross) for above 100MW and 0.33 capacity factor and 1100 lb/MWh for smaller plants between 25
and 100 MW and 0.33 capacity factor. Therefore, only plants that were equipped with partial carbon capture and sequestration (CCS) would be permitted.

-2-

SOLAR ENERGYThe SEP acknowledges that renewable energy is a promising energy source and proposes to encourage its use
through regulatory reform and additional research and development. However, the SEP concludes that
renewable energy has “various challenges in terms of stable supply and cost at this moment.” While conceding afuture role for small scale solar generation in distributed generation settings, the SEP concludes that“the power generation cost of solar power is high, and power output is unstable.
Therefore, further technological innovation is necessary. In the mid-to-long-term,
cost reduction is expected to promote the introduction of solar power based on
its position as an energy source which complements peaking demand in daytime
hours in the distributed energy system and which contributes to the implementationof energy management involving the participation of consumers.”
While further technical development will further reduce its cost, solar energy, particularly utility scale solar
energy is commercially available. Based on cost trends in the United States, Europe and elsewhere utility scalesolar energy should be competitive with fossil fuel fired generation in Japan by the time a new fleet of coal-fired
power plants could be constructed. Several years ago the United States Department of Energy (DOE)
established the SunShot program to reduce the cost of solar energy by 75 percent between 2010 and 2020. In its
most recent report on the project’s progress, the Lawrence Berkeley National Laboratory, which manages the
program for the U.S. DOE, provides hard data - actual costs of completed projects – that documents the very
dramatic decline in solar photovoltaic (PV) costs in just three years5 . While the data show a significant decreasein the cost of systems of all sizes, of most relevance to Japanese energy policy is the very large decrease inrecent years in the cost of utility scale solar PV. At an installed cost of 11.2 U.S. cents/kWh utility scale solar is
now cost competitive with natural gas peaking and load following generation and, when fuel price volatility isproperly considered, with new coal-fired generation. The most recent compilation of cost of generation fromdifferent sources reports an even lower cost of USD 72-86/MWh for utility scale solar6.

The Falling Price of Utility-Scale Solar Photovoltaic (PV) Projects

2020 Goal of 6 c/kWh

Figure 2. The falling price of Utility-Scale Solar Photovoltaic (PV) projects
Source: U.S. Department of Energy7

5. This report and the underlying data can be accessed at http://eetd.lbl.gov/sites/all/files/lbnl-6350e.pdf.
6. http://www.lazard.com/PDF/Levelized%20Cost%20of%20Energy%20-%20Version%208.0.pdf?utm_source=
Video+of+Sept.+18+event+with+Lazard&utm_campaign=GCC+-+Lazard+Event&utm_medium=email
7. http://energy.gov/eere/sunshot/photovoltaics-3-

The DOE study, cited above, reports that residential/commercial PV panel prices in Japan are slightly lessexpensive than in the U.S. The study also reports that Chinese PV panels are slightly less expensive than U.S.
panels8. Japans’ solar resources are among the very best in the world, far better than Germany or several U.S.
states with fast growing solar penetration.
The GOJ has undertaken several efforts to provide a startup impetus for renewable energy, including net
metering, portfolio standards and, most recently, a Feed In Tariff (FIT). The Japanese FIT specifies a tariff thathas been more than sufficient to spur the development of a truly significant amount of solar PV, but contains
features that sharply diminish the program’s effectiveness.
A Power Purchase Agreement (PPA) is a contract between the developer/owner of the generating asset (here,
the owner of the solar park) and the utility that then resells the electricity to the consumer. A long term PPA thatprovides a predictable revenue stream provides the basis for financing solar and other renewable energy projects.
While the Japanese FIT system does provide for a 20 year term, unlike successful European and U.S. FIT
programs, it does not provide for clear “take or pay” priority provisions that assure that the utility will purchasethe electricity that is generated. In the Japanese FIT legislation there are conditions under which Japaneseutilities can decline to accept the electricity produced by renewables, including a lack of transmission capacity.
The most recent data demonstrates that there continues to be a steady investment by individuals in solar PV.
Those data also demonstrate that something is preventing the large number of projects that have registered for thetariff from commencing construction. In the period from April, 2012 to December, 2014 solar projects with acapacity of 70,880 MW had registered and been certified, but projects totaling only 15,410 MW had commenced
construction. Some portion of the unbuilt projects has been attributed to speculators who submitted
registrations to obtain high tariff to get larger profits at its premature stage of development. The GOJ has
withdrawal of the registration for a number of these projects. The GOJ has expressed a concern that the large
capacity of registered projects would cause transmission system deficiencies in certain locations.
Hokkaido is a popular location for renewables and the Hokkaido Electric Power Company has reportedly
been authorized to curtail purchases of renewables, without limitation or compensation, once 700 MW ofrenewables are online in its system. On September 24, 2014, the Kyushu Electric Power Company announced
that it would temporarily suspend processing applications for grid connection of new renewables. The company
noted that in March of 2014 alone it had received 70,000 applications for grid connection and that the total
capacity of all wind and solar connection applications currently filed was 12,600 MW. Prior to adoption of the
FIT policy, Kyushu Electric had predicted that its 2020 renewable generation would be 3,000 MW. Shortly
thereafter Hokkaido, Tohoku, Shikoku and Okinawa announced similar restrictions on renewable generation.

8. http://eetd.lbl.gov/sites/all/files/tracking_the_sun_vii_report.pdf-4-In January, 2015, the GOJ revised the FIT provisions to lower the amount of the feed-in-tariff and to prevent
speculative registration of proposed projects where there was no concrete business plan to proceed with aproject. The GOJ also adopted a revision9 on the right of utilities to curtail purchases from utility scale
renewable generators, and introduced the notion of “real time” control of the amount of renewable generation(“output control”) by the Agency for Natural Resources and Energy (ANRE). Under these rules, The utilities
may limit renewable generation (including small scale renewable generation), without compensation to theoperator, based on the “grid access capacity” where nuclear and fossil fuel-fired plants, including newly
constructed power plants, would have a priority right to grid capacity.
The reduced FIT and cancellation of speculative registrations will not likely pose a significant barrier to thedevelopment of renewable energy in Japan, but the prospect that utilities can constrain output from renewablesources without compensation will continue to generate uncertainty about the ability of investors to make loan
payments and chill investment in renewable energy projects. The large utilities are in the best position to ensure
efficient integration of renewables, but lack a financial incentive to do so. Applying the “take or pay” principles
discussed herein provides that financial incentive and will likely be more efficient than ANRE regulation.
A long-term PPA, where the utility agrees to take all of the generation from the solar park, provides aguaranteed stream of revenue. The PPA, not the solar panels, is the important security for the loan needed tobuild the solar park. The developer assigns rights under the PPA to the lending institution. Renewable “take orpay” provisions provide a priority for renewable generation, with very low operating costs, over generation fromexpensive imported fossil fuels. Japan’s vertically integrated monopoly utilities would be required to accept alltechnically valid applications and ensure that sufficiently flexible transmission resources are available. If thegrid is not able to accept the renewable generation at certain points in time, the system operator can curtail
renewable generation to maintain grid stability, but the utilities are still required to pay for the curtailed
generation. These provisions are common in the U.S. and elsewhere in the world. They discourage delays by
utilities (whose profits may be reduced by competition from renewables) in upgrading the grid and provide
assurance to lenders that the loan for the renewable project will be serviced. Interest on the loan is one of the
major components of the cost of new renewables. PPA terms that increase the risk of default by the developer,
such as those described above, will prevent some projects from going forward; other projects may move forward,
but with higher interest rates that reflect the increased risk – and, for that reason, higher generating costs.

9. The revision shifted the scheme for limiting renewable electricity output without compensation for the operators of renewable energy power
generation facilities (so-called “30-day rule”) from a daily basis to an hourly basis-5-Distributed PV has many advantages and the SEP encourages the continued development of this technology.
Less visible is any indication of support for utility scale PV that is far less expensive than distributed PV andwould normally be expected to play a significant role in development of low cost power options for Japan.
The International Energy Agency (IEA) reports that the cost of solar PV has already reached grid parity withother forms of energy, including new coal-fired generation, in many countries10. As a result, the IEA projects
that solar PV in Japan will grow at a rate of 3-4,000 MW per year, reaching 50,000 MW by 2020. Afteraccounting for the differences in capacity factor, this is more capacity than is needed to offset the proposed newcoal-fired power plants. In Germany, where the solar resources are less valuable than in Japan, the FIT for new
solar projects has been reduced to 13.01€c/kWh (18 ¥/kWh) for new small roof mounted systems and9.01€c/kWh (12¥/kWh) for land-based systems. This step was taken to manage costs and implementation issues
at far higher levels of penetration than are contemplated in Japan over the next few years. The FIT is now lessthan the end user electricity price paid by some of the major industrial enterprises, less than half of the grosselectricity price paid by households and less than the estimated full costs for electricity from fossil and nuclear
plants11. The reduced FIT has reduced the number of new PV projects. 1,000 MW of projects were added in thefirst half of the year, new projects of 2,000 MW of new solar can be expected to be added to the 32,500 MW ofalready installed capacity.
Local PV developers in Japan claim that their costs are much higher than those reported in the U.S., Europe
or China, even though PV panel prices in the U.S. and Japan are comparable. It is not unusual for “first of akind” projects to have higher prices than later projects, but there is enough experience worldwide and in Japanthat there should not be a large difference between Japanese projects and others (especially in light of Japan’s
relatively high levels of solar insolation). It may be that there is an unusually high cost to construct newtransmission capacity to connect individual projects to the grid. These claims may also be based on prices
reported several years ago, before the price cuts in recent years. Or it may simply be the fact that landowners
have anticipated the FIT and adjusted their land rents based on the level of the FIT. The large number ofregistrations for large scale PV suggests that many potential developers, including some who may simply be
speculators looking to sell the development rights to others, found the current FITs to be attractive. This issue isextremely important, as a FIT that is too high can be as much a barrier to the long-term implementation ofrenewables in Japan as a FIT that is too low.

10. http://www.iea.org/media/freepublications/technologyroadmaps/solar/TechnologyRoadmapSolarPhotovoltaicEnergy_2014edition.pdf
11. http://www.ise.fraunhofer.de/en/publications/veroeffentlichungen-pdf-dateien-en/studien-und-konzeptpapiere/recent-facts-about-photovoltaics-in-germany.pdf-6-

WIND ENERGYThe GOJ estimates that Tohoku, Hokkaido and Kyushu have over 1,000,000 MW of potential wind energy.
Japan’s wind resources were developing at a very modest, but steady rate of approximately 250 MW/year
from 2001 to 2011. Thereafter, wind power development dropped to approximately 50 MW/yr, even as wind
power costs continued their steady decline. This decline coincided with the 2011 revision of Japan’s
Environmental Impact Assessment (EIA) law. Under this law a developer can build a 149.9 MW coal-fired
power plant, with the attendant stack emissions, fugitive emissions and water quality issues associated with coaland ash piles, and noise - all without conducting an EIA12. However, if a developer wants to construct a 10
MW wind or geothermal site, a full EIA is required. At the current FIT a 10 MW project that (just four 2.5 MW
wind turbines) would generate a gross revenue of less than USD 6 million per year and net profits of several
hundred thousand dollars per year. The obligation to conduct an expensive and time consuming EIA for such
relatively small projects is a much larger obstacle than an EIA for a 1200 MW thermal project or for a large
concentrated wind farm that would generate much, much larger revenues. This requirement discriminates
against wind projects in general and discourages the development of smaller, disbursed wind projects that may
be less objectionable from an aesthetic perspective and that would reduce the intermittency of wind power by
disbursing the wind turbines over a wider area.
This is not to suggest that environmental concerns with wind power should be ignored or minimized. Wind
farms are without doubt industrial facilities and concerns over noise, shadow flicker and bird strikes arelegitimate. Other countries have adopted strategies that address these issues in sensible and effective ways. In
the U.S. the requirement for site specific studies is often limited to wind farms of 70MW or larger. Low
frequency noise and shadow flicker issues can be addressed by establishing set back requirements throughzoning laws that govern how far from the property line units of a given height may be installed, rather than
expensive site specific studies. Various state governments and/or the Federal government have sponsored
flyway studies and delineated areas that are not of concern for bird strikes and industry groups have consulted
with government agencies and environmental organizations and published best practice requirements. Theseobligations can be incorporated in generic permitting documents that can be used to fast track projects
employing best practices and that do not raise site specific issues.
The recently released International Energy Agency (IEA) Wind power Report13 forecasts that new wind
power installations in Japan may return to 200MW/yr levels as EIA studies underway are completed and projects
go forward. However, understanding that wind projects typically have capacity factors of 30 percent or less, 200
MW/yr of new wind is equivalent to 60 MW of fossil fuel capacity. This rate of increase in actual generation is
far too slow a pace to address Japan’s needs. By way of comparison, the U.S. state of Texas, which has apopulation one-fifth of Japan’s, has added an average of 1,600 MW/yr in the period from 2006 to 2015. If Japan
were to add 1,600 MW/yr of wind over the next ten years, the generation from wind power alone would be
sufficient to offset the generation from the proposed new coal-fired generation14. And so, Japan would not needto add new coal generation and could reduce imports of high priced fossil fuels.

12. A simplified EIA may be required for 112.5-149.9MW power plants.
13. http://www.ieawind.org/annual_reports_PDF/2013/Japan.pdf
14. Or 3,200 MW/yr for the next 5 years. The total capacity needed is approximately 0.016 percent (16/10,000) of the estimated wind capacity of
Hokkaido and Kyushu Islands.

-7-

8,352

8,852

7,326

1,534

Figure 3. ERCOT Wind Installation by Year15
The SEP correctly notes that in Japan, as in many other parts of the world, the most valuable wind resources
are not adjacent to the large cities that need the power.
“Wind power is an energy source which has a potential to be capable of securing
economic efficiency, since the power generation cost is close to that of thermal
power generation when developed on a large scale. However, while there issufficient load following capacity to adapt to changes in supply volume in a service
area where demand is large, that is not necessary the case in areas suited to wind
power, such as Hokkaido and the northern part of Tohoku. Therefore, it is necessary
to develop transmission lines, to secure sufficient load following capacity throughbroad-area operation of power grids and to utilize storage batteries. GOJ needs topromote the utilization of wind power while taking economic efficiency into consideration.”
This is certainly true in Texas, South Dakota and other U.S. states that have experienced a rapid growth in RE
development. The history of the wind power development in Texas is illustrative of the nature of governmental
support needed to develop new energy resources. Several years ago the Texas legislature passed a law requiring
the electricity system operator to develop a grid system capable of supporting Texas’ wind resources. That law
provided a funding mechanism where the ratepayers throughout the state supported the necessary projects inremote, but windy areas of the state known as “Competitive Renewable Energy Zones” (CREZ). Now
completed at a cost of nearly USD 7 billion, the CREZ projects involved 186 separate projects, including 345 kVtransmission lines and network upgrades spanning 3,600 miles. It has the capacity to transmit approximately
18.5 GW of wind energy from remote windy areas to Texas’ large cities. With knowledge that the electricity
can be transmitted to markets at reasonable cost, developers have added generating capacity. Again, the added
wind power in Texas in the past few years alone, made possible by an act of the Texas legislature, is nearly at ascale needed to replace the proposed new coal-fired power plants in Japan.

15. ERCOT Monthly Operational Overview (April 2014)
http://www.ercot.com/content/committees/board/keydocs/2014/ERCOT_Monthly_Operational_Overview_201404.pdf, page 17-8-

In considering the Texas experience it is important to understand that Texas is not California. The Texas
legislature, like that in South Dakota, Kansas and a number of other states that are rapidly expanding wind andsolar power generation, is a conservative body. The Texas legislature did not enable the CREZ zones to limit
emissions of greenhouse gases. It did so to create wealth for its residents and lower based on valuable windresources that would not likely be developed without legislative action. Texas’ electricity rates are less than the
U.S. national average and the same or less than nearby U.S. states that rely more heavily on coal-fired
generation. The new renewable generation in Texas has proven to be price competitive with natural gas-fired
generation, even though Texas has significant non-conventional (fracked) natural gas that is priced far lower
than LNG imported in Japan. In its discussion of wind power the SEP correctly notes that integration of wind
power is easier where there is a large integrated system and suggests that this factor makes integration of wind
power more difficult in Japan than in the U.S. However, most of Texas is not interconnected with the rest of theUnited States. The major load centers and the major wind power generating facilities in Texas are isolated fromthe rest of the U.S. grid and so the Texas example provides a good demonstration of what can be accomplishedin Japan.
The SEP incorrectly asserts that wind power is somewhat more expensive than new coal-fired generation andstates that “[t]here is also the problem of a wind blade falling”. Occasional turbine blade failures wereexperienced earlier in the development of the technology, but that problem was solved more than a decade ago.
Wind power is generally recognized as having a lower cost than new conventional pulverized (PC) coal plants
and a substantially lower cost than the new Integrated Gasification Combined Cycle (IGCC) coal plants thatJapan is promoting16.

Figure 4. Declined cost of wind energy in US
Source: American Wind Energy Association17

16. http://www.lazard.com/PDF/Levelized%20Cost%20of%20Energy%20-%20Version%208.0.pdf
17. http://www.awea.org/Resources/Content.aspx?ItemNumber=5547-9-

The SEP provides little specific support for land based wind power, but provides greater policy support foroffshore wind power. Most notably, the SEP leaves development of the transmission resources needed to fully
develop land-based wind power to a hoped for agreement between wind power developers and Japan’s verticallyintegrated power generators. A tradeoff is between land and offshore wind power is unnecessary as bothresources can be developed. On the other hand, the SEP sees promotion of offshore wind power is inevitable for
mid and long term. However, promotion of offshore wind power in lieu of land based wind power is also
generally viewed skeptically within the environmental community, as is carbon capture and sequestration (CCS).
Advocates for the continued use of coal have in recent years feigned support for each of these technologies, but
only for so long as actual implementation remained in the distant future. As CCS and offshore wind projects
reached the point of commercial implementation, industry support in the U.S. and elsewhere evaporated becauseof the high intrinsic costs of these technologies. Some governments, notably the German government, appear to
be serious about actual implementation of offshore wind power, notwithstanding today’s costs. There is no
reason why development of offshore technology should not proceed so that in the future it will prove to be useful
and affordable. But the potential for offshore wind power at some undefined point in the future should not be used
as an excuse to defer development of the technologies that are available today. Development of land based wind
power and utility scale solar power can and should continue, both as a bridge to the time when offshore wind
implementation is feasible and cost effective and as a complementary power generation option.

- 10 -

COAL FIRED GENERATIONThe SEP promotes the construction of new coal-fired generation asserting that (1) coal has the lowest
geopolitical risk and (2) the lowest price per unit of heat energy - among fossil fuels. It also promotes the use of
new technologies, such as integrated gasification and combined cycle facilities (IGCC), that it claims“drastically” reduce greenhouse gas emissions per unit of generated power. The SEP further claims that it is, infact, “necessary” to use coal domestically, but to promote the use of Japanese coal combustion products
internationally. Japan has in the past few years aggressively marketed Japanese supercritical pulverized coal
(SCPC18) generating systems throughout the world.
First, it should be understood that neither coal gasification nor supercritical combustion technology is a newtechnology. Coal gasification was first discovered in the 1600s and was widely used throughout the U.S. andEurope for lighting, heating and cooking. Prior to World War II, 20,000 coal gasifiers were operating in the
United States. After World War II, petroleum replaced coal gas throughout most of the world, with the notable
exception of South Africa, whose apartheid policies required the continued reliance on gasified coal. With thefirst oil shocks in the 1970s, interest in coal gasification revived and the first IGCC plant was constructed in the
U.S. As oil prices receded, so did interest in IGCC plants, but with the increase in oil prices in the 1990s several
new IGCCs were constructed in the U.S. and Europe. As of 2010 there were 144 IGCC plants, with 427
gasifiers operating in 27 countries19.
Supercritical combustion technology involves operation at the elevated temperature and pressure conditions.
This technology was first developed in the U.S. in the 1950s. It was adopted in Japan in the 1960s and has
evolved with incremental improvements throughout the world since that time. There are over four hundred coalor lignite-fired SCPC/USCPC/AUSCPC steam electric generating units in service around the world today.
Further, these technologies do not “drastically” reduce greenhouse gas emissions per unit of generated power.
These technologies reduce CO2 emission rates by 10-15 percent compared to modern subcritical units, not atrivial amount, but by no means a “drastic” reduction. Replacing existing LNG-fired units with even the mostefficient IGCC technology effectively doubles the rate of emissions. And replacing an existing coal-fired unit,
even a unit with a relatively poor emission rate effectively increases the lifetime emission rate of than unit by afactor of two to ten, depending on the remaining useful life of the unit. If the older, low efficiency unit isassumed to operate for 5 to 10 more years, it can be reasonable assumed that at that time the replacement
generation will be from renewables or geothermal power. But if that unit is replaced by an IGCC in the nearterm, the operator of that unit will be locked into generating using coal for as long as society will permit. Most
importantly, the level of reduction from implementation of higher efficiency coal-fired units is not sufficient toqualify this resource as part of a meaningful solution to the problem of climate change. It should be noted that,while SCPC/USCPC/AUSCPC generating costs are roughly equivalent to SCPC costs, IGCC generating costs
are substantially higher.
Lastly, the SEP offers no factual support, or even rational argument for the claim that the increased use of
SCPC or IGCC generation, both domestically and internationally, is somehow “necessary,” given the available
alternatives. No fact-based argument has been presented to show that Japan must have new coal-fired
generation. Further, no facts have been put forward to show that new coal units are “necessary” in Viet Nam,
Myanmar or any of the other countries that are targets of the GOJ/JBIC aggressive coal unit marketing andlending policies or that the Japanese economy will suffer if the country were to decide to export highly advanced
renewable technologies rather than coal burning technology.

18. As temperature and pressure increase, so does efficiency. Following the trend towards higher operating temperatures and pressures, these units are
now being described as ‘Ultra-supercritical” (USCPC) or “Advanced Ultra-supercritical” (AUSCPC), but there is no additional thermodynamic
phase change involved as there is in the transition from subcritical to supercritical operating conditions.
19. http://www.netl.doe.gov/research/coal/energy-systems/gasification/gasifipedia/history-renewed- 11 -

Japanese utilities and wholesale power utilities operate approximately 442,000 MW of coal fired capacity,which provides 28percent of Japan’s electricity. The reports in 201420 indicated that Japan’s regional generating
monopolies are planning to add 11,000 MW of new fossil fuel generation over the next 14 years, including 1,800
MW of new gas generation, 3,500 MW of new coal generation and 7,000 MW of undetermined fossil fuelgeneration. Encouraging such development, the SEP boldly asserts that:“crude oil and natural gas prices will keep tendency of rise. The prices seem tobe kept at today’s level or further rise due to robust demands in emerging
countries. On the other hand, the coal price will be relatively stable.”
Once a multi-billion dollar investment in new fossil-fuel fired generating capacity is made, the owner islocked into that fuel for 40 to 60 years. It is impossible to forecast with any level of accuracy the price of any
fuel more than a few years into the future. A review of recent forecasts of the price of natural gas shows that the
U.S. estimates of prices just four years into the future were wrong by 100 percent. The actual price of natural gas
in 2013 was half of that predicted for 2013 in 2009, even though the government was fully aware of thedevelopment of non-conventional shale gas. Contrary to the assertion in the SEP, long term volatility in coalprices is similar to oil and gas. The charts below set out the prices for various fossil fuels over the past twenty
years. Here we see that the peak coal price in that period is approximately six times the average of the early
period. This is roughly the same as the ratio of peak to early average shown for the other fossil-fuels – and, as
shown later, for nuclear fuel. History has demonstrated that specific events that cannot be predicted, such as
flooding in Australia or Indonesian coal export policy decisions, can have significant impact on the price of coal.
The difference between coal and LNG prices is not the degree of potential volatility, but the fact that coalprices are lower than LNG prices at this moment. But there is no basis to predict that this will remain the caseover the next 40-60 years. It takes several years to add coal production capacity. As coal prices rose andpredictions of huge demand increases were made, producers expanded supply significantly in recent years. But
the anticipated demand did not appear and there is currently an oversupply of coal. A number of producers
have declared bankruptcy while others have closed mines and fired thousands of workers to scale backproduction and rebalance prices. Coal analysts report that coal producers are now selling below cost, so that
there is no real probability that prices will be significantly lower for any sustained period of time. As supply isrebalanced to more closely match demand, it is reasonable to anticipate that prices will rise, the price andforward volatility will depend on the ability of producers to anticipate demand and their appetite for risk ofadditional losses from oversupply.
As the European/US Natural Gas Chart below demonstrates, there is a potential for lower gas prices (andpresumably lower LNG prices over the next several decades) if U.S. technology to develop nonconventional
natural gas reserves proves to be applicable in Asia and elsewhere.

20. http://www.reuters.com/article/2014/03/28/japan-utilities-plant-idUSL4N0MN1X520140328- 12 -

Coal Prices (Aus)

LNG Prices (Japan)

Oil Prices (Aus)

U.S. & European Gas Prices
EU

U.S.

Figure5 Fossil Fuel price- 13 -

Figure 6. Exchange rates: Japanese Yen vs. Euro and U.S. Dollar, 1990-2014
Indeed, the recent natural gas prices for the U.S. are much closer to 1994 levels than are coal prices. The
fundamental point is that no one can predict what will happen to prices of these commodities decades into the
future. No one anticipated either the sharp run up in fossil fuel prices prior to the oil shocks of the 1970s or the
Iran and Iraq hostilities of recent years, or the steep drop in U.S. gas prices associated with horizontal drillingand fracturing. Historically, incorporating the risk of fuel price volatility in energy decisions was not asimportant as it is today. In the past coal and gas prices were linked to the price of oil, so that as oil prices rose orfell, so did the price of coal and gas. The theory was that the operator was simply purchasing the heat content of
the fuel and the prices of the different forms of providing that heat content should simply reflect the heat content
of the fuel. In recent years, the linkage between oil and other fuels has been severed, with by U.S. natural gas
prices no longer linked to oil prices, but also to a lesser degree with coal21 prices. Generating efficiencies withfired CCGT are substantially higher than coal units (including IGCC), so that the cost per unit of electricity
generated are closer than they appear in the charts of the cost per unit of heat input published by METI.
More importantly, fossil fuel-fired generation now must compete with energy resources, such as wind and solar
power, where the fuel cost is known to be zero and known to be non-volatile. Japanese policy does not appear torecognize the price premium that should be incorporated to account for the fact that fossil fuel fired-generationnecessarily bears a risk of price volatility and exchange rate volatility over time. Even without this consideration
wind power is priced lower than new gas or coal power and solar power is competitive with peak power prices
during daylight hours. If Japan’s policy makers include a reasonable premium to account for these risks,
renewables will clearly be shown to be less expensive than either new coal or LNG-fired generation going forward.

21. A portion of the cost of internationally traded steam coal is the cost of transportation which is still linked to the price of oil.

- 14 -

GEOTHERMAL ENERGY
Japan is also blessed with the third most abundant geothermal energy resources in the world. Estimates place
the developable resources about 33,000 MW. This form of energy generation can be dispatched as base loadenergy and can be developed as a mix of small and larger projects. Unlike solar or wind power, which areintermittent generating technologies, geothermal energy production has a capacity factor similar to base loadcoal and nuclear power. In the thirty year period from 1966 to 1996, 520 MW of geothermal generation was
installed in Japan, but then development ceased until very recently. Barriers to development include the fact thatmany of the developable sites are in national parks. In addition, operators of onsen have raised concerns thatgeothermal power generation will drain the hot springs and ruin a cherished form of relaxation and source of
tourism income. In addition, the hiatus in development of this resource in Japan has stalled technicaldevelopment that can reduce cost.
As with solar power, the SEP offers kind words and research for the mid to long-term development of theresource, but no specific policies to aggressively promote this resource:“[c]onsidering such merits, based on mid-to long-term perspective, GOJ studies
arrangements for site location in order to continue promoting sustainable
development with regions”.
A FIT of 40¥/kWh for smaller projects and 26¥/kWh for projects greater than 15 MW is provided. There arevery few capacities registered for the FIT. In April of 2014, the first new geothermal plant in 15 years opened in
Kumamoto prefecture in Kyushu. Some additional projects are planned throughout Japan, but the initialdevelopment process is slow, in part because any geothermal project greater than 10 MW must undergo a full
EIA. In addition, as with wind and solar power, the utilities need not take all of the power that the source
generates and can refuse interconnection based on lack of transmission capacity. Advocates of this technology
express hope that, as the first few projects are developed, public acceptance of this form of power generation will
improve. “Take or pay” PPA’s that are commercially acceptable to lenders and an upgraded transmission system
can help dramatically expand the use of this valuable resource.

- 15 -

NUCLEAR ENERGYWith regards to safety, the SEP candidly acknowledges that“[t]he TEPCO’s Fukushima nuclear accident exposed the fact that countermeasuresagainst severe accidents were lacking. The Japanese government and nuclear
operators must continue to reflection the fact that they fell into the trap of theso-called “safety myth” and brought about a situation in which disaster victims
and other people are suffering significant hardships.
The SEP asserts that new, post Fukushima accident, “which are of the most stringent level in the world” canguarantee a level of safety that may allow reopening an unspecified number of units that are currently closed.
The adopted SEP asserts that the operational cost of nuclear power is low and stable and proposes to allow
restarting nuclear units once the Nuclear Regulation Authority (NRA) confirms that the units are in compliancewith the new regulations. As we have seen above, the SEP rejects or delays implementation of renewable energy
technologies and continued reliance on LNG, on the basis that these technologies are too expensive, but thepolicy asserts that Japan should move forward with restarting its nuclear plants.
However, in order to evaluate whether alternate options are too expensive than those adopted in the SEP,
one needs to know the cost of the favored options. Until Japanese authorities have publicly discussed theextent and cost of their proposed upgrades to nuclear plants they cannot conclude that nuclear power ischeaper than renewables.
Standard reliability theory
posits what is known as the
Weibull bathtub curve, where
failures occur early in a unit’s life,
then stabilize at a low rate of
random failures for a period oftime, and then escalate as the unit
reaches the end of its economic
life. In the U.S. and elsewhere anumber of nuclear units haveclosed (or are scheduled to close)
because the cost of ongoing
maintenance needs has rendered
Figure 7. The Bathtub Curvethese units unprofitable. A proper
evaluation of the cost of restartingsome or all of Japan’s nuclear units should include a public discussion, based on plant operating records, of the pastand projected maintenance costs as well as the cost of upgrading the plant to meet new requirements and adetermination of the remaining useful life of those units and a determination of the Levelized Cost of Electricity(LCOE) for the generation from those units in comparison with the alternatives. Several U.S. nuclear generation
units are facing closure because of the inability of the unit to compete with lower cost options, including gas-fired
CCGTs and wind power.

- 16 -

Any evaluation of the cost ofrestarting Japan’s nuclear fleet should
also include a public discussion, basedon prior date the cost of storing andreprocessing nuclear waste. In Japan,
as in the U.S., this issue has eluded
policymakers for over half a century.
Given the long time frame for final
storage, the need to monitor andpotential need for remedial activities atvarious points over the next 100,000
years, these costs may be material toany cost comparison with renewables.

U.S. Uranium Fuel Prices

Figure 8. US Uranium Fuel Prices
Source: USEIA

Further, any cost comparison
should include a discussion andevaluation of the cost, and cost volatility of fuel reprocessing and virgin nuclear fuel purchases. In the U.S.
uranium fuel prices have increased by roughly the same percentage as fossil fuels in recent years.
In addition to a risk premium for future fuel price, reprocessing and storage volatility any evaluation of thecost of restarting nuclear plants compared with reasonable alternatives should include a risk premium forcatastrophic accidents. It may be difficult to quantify this premium, since commercial catastrophic risk
insurance is not available. However, as events in Fukushima have shown, there is a cost to these uninsured
events that is some non-zero amount per kWh of electricity. Best efforts should be made to arrive at a consensus
figure (or range of estimates) that is then applied to the projected cost of future nuclear generation.
New nuclear generation is among the highest cost electricity options in the U.S. When and if the cost of
upgrades to meet new safety requirements is considered, along with the increase in maintenance costs that is
associated with older units, and appropriate fuel price volatility and catastrophic risk premiums, it is highly likelythat renewable energy will be found to be more cost effective than restarting nuclear units.

- 17 -

ENERGY EFFICIENCY (EE)As with other technologies the SEP mentions EE, and concludes that EE is a good thing. But the SEP fails to
discuss the relative cost of EE to other options. This is highly significant in Japan, since much of the shortfall
from the idling of nuclear units has been made up by EE efforts. Further, EE is widely recognized as the lowest
cost option for satisfying energy demand. The SEP also fails to set out specific policy, in terms of actions to betaken by the GOJ, or of a national goal for EE that the GOJ will work towards.

HEAT RATE IMPROVEMENTS, BETTER PLANT O&M
AND RETIREMENT OF LEAST EFFICIENT UNITSThe SEP claims that coal thermal power is “superior in terms of stable supply and economic efficiency”, but
acknowledges a problem in that “it emits a large amount of greenhouse gases.” To “resolve this problem” theSEP proposes to shorten the EIA review period from three years to one to encourage the development of
SCPC/IGCC technology. The SEP also incorporates the long-standing promise of the coal industry to conduct“research” on CCS. Finally, the policy incorporates a highly controversial policy decision to promote newcoal-fired generation throughout the world.
Within Japan, however, many of the existing coal-fired units have reasonably high design efficiencies. Somein Japan assert that Japan’s fleet of coal-fired EGUs has the highest average operating efficiency in the world.
The SEP does not propose to scrap the existing fleet and replace it with new IGCCs. The utilities have identified
plans to add new coal capacity that is a relatively small percentage of the existing coal capacity. While this levelof new capacity additions will extend Japan’s dependency on foreign sources of coal, it will not significantly
reduce the cost of generation of electricity or reduce the trade deficit associated with importing coal. However,there are measures available that can improve the fuel efficiency of Japan’s coal oil and gas-fired generating
units and reduce CO2 emissions without locking Japan into a long term need to purchase fossil fuels. Nowhere
does the SEP discuss the potential for reduced emissions and import of fossil fuel associated with Heat Rate
Improvements (HRI)22 at existing units.
The literature23 points to recently developed technologies that can improve the operating efficiencies ofexisting units, particularly units that are more than 10 or 15 years old. These technologies include neural nets24
to optimize combustion, advanced seal designs, intelligent sootblowing25, and advanced steam turbine designs.
These technologies each improve the efficiency of existing units by small percentages that range from 0.1
percent to 3 percent. In combination, they can provide a substantial improvement of up to four percent in theperformance of existing coal units and a smaller improvement in other thermal units.

22. The “heat rate” of a unit is the engineering term used to describe the efficiency of the unit. For thermal power plants it is the amount of heat energy
needed to produce a unit of electricity and is often described in terms of heat input in British Thermal Units consumed by the unit to produce athousand watts of electricity for an hour or Btu/kWh. Metric terms are also commonly substituted for the British units described here. The heatrate is comparable to the fuel economy of a car, expressed in liters/kilometer – lower is better.
23. http://www.iea.org/publications/freepublications/publication/PartnerCountrySeriesEmissionsReductionthroughUpgradeofCoalFiredPowerPlants.pdf
24. A “neural net” is a system of sensors placed throughout the combustion process and computer algorithms to manage and optimize combustion on a real time basis.
25. “Sootblowing” refers to the process of cleaning internal components to improve heat transfer and unit efficiency- 18 -

Larger improvements may also be available by increased attention to the operation and maintenance ofexisting units. Japanese utilities, like their American counterparts are likely to claim that they are alreadyoperating their units at the highest levels of efficiency throughout their lifetime. However, the operating recordsof U.S. utilities show that this is not the case. Large variations, that at times exceed 10%, have been observed in
the annual efficiency and CO2 emission rates of existing units (Figure 6)26. These differences vary substantiallybetween plants and are believed to be associated with differences in operating and maintenance practices at theseplants. Given the stress of the post-Fukushima period, Japanese coal-fired plants have been operated at higher
capacity factors than previously and may have deferred maintenance necessary to ensure the highest efficiency
and lowest CO2 emission rates. The potential for low-cost GHG emission reduction and fuel cost savings is not
mentioned in the SEP and apparently has not been investigated.

TVA Plant Allen Unit One
Daily Average CO2 Emission Rate2008 - 2013

Figure 9. TVA Plant Allen Unit One, Day Average CO2 Emission Rate 2008-2013
Source: EPA Air Markets program Data

26. See, www.regulations.gov, Docket Number EPA-HQ-OAR-2013-0602-25475. Exhibit A to comments of the SierraClub and Earth Justice,
Daily Average CO2 emission rates for representative U.S. coal fired power plants.

- 19 -

Note that the CO2 emission rate for this unit in the US over the most recent two years is approximately 10%
higher than the prior three years (Figure 7). And so, the fuel economy of this unit has degraded by 10% without
correction. The author and the Sierra Club anticipate publishing the results of a comprehensive evaluation ofthis issue over a representative sample of the U.S. coal-fired EGUs in the next few months. Though lessfrequent, similar decreases in efficiency that can be corrected have been observed in the operation of U.S.
combined cycle gas turbines:

West Phoenix Unit 6A Monthly Emission Rata

Figure 10. West Phoenix Unit 6A Monthly Emission Rate, Source
USEPA Air Markets Program Data

In contrast to the SEP proposals, the actions needed to secure CO2 emission reductions – and reduced fuelcosts – for Japanese consumers need not involve large capital expenditures that then lock investors andconsumers into additional decades of reliance on expensive imported fuels. Japan’s current natural gas fleet ishas sufficient capacity to provide intermittent support for widely dispersed renewable generation.

- 20 -

U.S. CARBON ACTION PLAN AND PROPOSED REGULATIONS
Under President George W. Bush, the U.S. provided little or no climate policy development or leadership.
President Obama, on the other hand, has expressed his understanding of the need to address this critical issue.
Conservatives in the U.S. Congress have sufficient power to block any broad-based legislation and so the Obama
Administration has undertaken a number of administrative actions that, while not ideal, will result in asignificant reduction in U.S. carbon emissions and provide a demonstration of U.S. leadership that may help
secure broader global agreements. The Administration’s actions commenced with a modest increase in somemotor vehicle fuel economy standards in 2011. In April, 2012, the U.S. EPA issued a determination that CO2 is
a pollutant under the U.S. Clean Air Act and promulgated of a fuel economy standard for passenger motor
vehicles of 54.5 miles per gallon by model year 2025. Rules that will require similar dramatic reductions in CO2emissions from larger vehicles are proceeding.
Then, the Obama Administration has proposed a series of regulatory and administrative actions that will
dramatically change the course of electricity production and use in the U.S.
• Limits on carbon emissions from new fossil-fuel fired plants. The proposed limits are set at levels thatprohibit the construction of new coal-fired plants that do not employ partial carbon capture and sequestration(CCS) and limit the use of gas-fired combustion turbines (CTs) to peaking applications. A final rule isscheduled to be issued by June, 2015.
• Limits on carbon emissions from existing coal-fired power plants. As proposed, the limits, to be
implemented by states on a state-wide average basis, would achieve emission reductions equivalent to a
formula that includes:o heat rate improvement at fossil fuel power plants;o shifting dispatch from coal-, oil-, and natural gas-fired steam generation to less carbon intensive combined
cycle natural gas generation;o increasing renewable generation; ando increasing demand-side energy efficiency.
The low-cost compliance option for complying with the proposed limits is retiring up to 100 GW of existingcoal-fired capacity and replacing that capacity with renewables. Overall emissions from this sector are predicted
to be 30 percent or more below 2005 U.S. CO2 emission rates. A final rule is scheduled to be issued by June,
2015. Compliance with the different components of the rule occurs in the period between 2020 and 2030.
However, as proposed, 80 percent of the emission reductions will occur by 2020.

- 21 -

• U.S. generation from wind, solar and geothermal sources doubled from 2008 to 2012. The Administration
has adopted a goal to redouble it by 2020. To achieve that goal the Administration is taking the following
specific steps:o In 2012 the President set a goal to issue permits for 10 gigawatts of renewables on public lands by the endof the year. The Department of the Interior achieved this goal ahead of schedule and the President has
directed it to permit an additional 10 gigawatts by 2020.
o The Administration has committed to develop and demonstrate improved permitting procedures forhydroelectric power at existing dams, the Administration has designated the Red Rock Hydroelectric Plant
on the Des Moines River in Iowa to participate in its Infrastructure Permitting Dashboard
for high-priority projects.
o The U.S. Department of Defense – the single largest consumer of energy in the United States –is committed to deploying 3 GW of renewable energy on military installations by 2025.
o Federal agencies have been directed to streamline the siting, permitting and review process fortransmission projects across federal, state, and tribal governments to facilitate the integrationof renewable energy.
o Federal agencies have been assigned a goal of reaching 100 megawatts of installed renewable capacity
across the federally subsidized housing stock by 2020. This effort will include conducting a survey ofcurrent projects in order to track progress and facilitate the sharing of best practices.
o The Federal budget increases funding for clean energy technology across all agencies by 30 percent,to approximately $7.9 billion.
• The Administration also committed to a range of new steps geared towards achieving President Obama’s
goal of doubling energy productivity by 2030 relative to 2010 levels:o The U.S. Department of Energy will establish efficiency standards for appliances and federal buildings set
in the first and second terms combined will reduce carbon pollution by at least 3 billion metric tons
cumulatively by 2030.
o The Department of Agriculture’s Rural Utilities Service will finalize a proposed update to its Energy
Efficiency and Conservation Loan Program to provide up to $250 million for rural utilities to financeefficiency investments by businesses and homeowners across rural America.
o The Administration established a business/government partnership to achieve a 2020 goal of cuttingenergy use by an average 2.5 percent annually from U.S. commercial and industrial buildings andmultifamily housing.
• In addition to reducing emissions of CO2, the Administration’s Clean Power Plan includes commitments to
reduce emissions other greenhouse gases.
o The Administration has incorporated an incentive in its fuel economy and carbon pollution standards forcars and trucks to encourage automakers to reduce hydroflourocarbon (HFC) leakage and transition awayfrom the most potent HFCs in vehicle air conditioning systems.
o The U.S. EPA has committed to use its authority through the Significant New Alternatives Policy Program
to encourage private sector investment in low-emissions technology by identifying and approving
climate-friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives.
o The Administration has commenced an effort to develop a comprehensive, interagency methane strategy.
The group will focus on assessing current emissions data, addressing data gaps, identifying technologies
and best practices for reducing emissions, and identifying existing authorities and incentive-based
opportunities to reduce methane emissions.

- 22 -

o Across the economy, there are multiple sectors in which methane emissions are to be reduced, from coalmines and landfills to agriculture and oil and gas development. For example, in the agricultural sector,
over the last three years, the Environmental Protection Agency and the Department of Agriculture haveworked with the dairy industry to increase the adoption of methane digesters through loans, incentives,and other assistance.
o Across the economy, there are multiple sectors in which methane emissions are to be reduced, from coalmines and landfills to agriculture and oil and gas development. For example, in the agricultural sector,
over the last three years, the Environmental Protection Agency and the Department of Agriculture haveworked with the dairy industry to increase the adoption of methane digesters through loans, incentives,and other assistance.
o In the oil and gas sector, investments to build and upgrade gas pipelines will reduce emissions andenhance economic productivity, while EPA develops Federal standards governing release of methane
during development of nonconventional natural gas (fracking) and processing and distribution ofnatural gas.
o The Administration is working to identify new approaches to protect and restore U.S. forests, as well asother critical landscapes including grasslands and wetlands, in the face of a changing climate.
• The Climate Action Plan calls for the Federal Government to exhibit leadership in its purchases andfacility operations:o Under the Obama Administration, federal agencies have reduced greenhouse gas emissions by more than
15 percent and have established a new goal: The federal government will consume 20 percent of its
electricity from renewable sources by 2020 – more than double the current goal of 7.5 percent.
o On December 2, 2011, President Obama signed a memorandum entitled “Implementation of Energy
Savings Projects and Performance-Based Contracting for Energy Savings,” challenging federal agencies,
in support of the Better Buildings Challenge, to enter into $2 billion worth of performance-based contracts
within two years. Performance contracts drive economic development, utilize private sector innovation,and increase efficiency at minimum costs to the taxpayer, while also providing long- term savings inenergy costs. Federal agencies have committed to a pipeline of nearly $2.3billion from over 300
reported projects.
o In order to increase access to capital markets for investments in energy efficiency, the Administration has
committed to develop a standardized contract to finance federal investments in energy efficiency.
The U.S. environmental community continues to pressure the Obama Administration to make more vigorous
effort and the U.S. Congress to finally recognize the seriousness of the challenge posed by climate change.
However, the lengthy and specific list of actions and commitments undertaken in the past 6 years by the U.S.
government stands in sharp contrast to the nonspecific and unfulfilled commitments set out in the SEP.

- 23 -

TRANSPARENCY ISSUESThe SEP acknowledges that a lack of transparency in certain areas has led to reduced public confidence inJapan’s institutions, including both the plant operators and the GOJ itself.
“Since before the TEPCO’s Fukushima nuclear accident, publicdistrust of energy-related administrative organizations andbusiness operators have grown due to many troubles andscheduling delays related to nuclear energy policy, including
cover-up of accident information, problems related to the Monju
fast reactor, repeated delays in the start of operation at Rokkasho
Reprocessing Plant, and delays in selecting a final disposal site
for high-level radioactive waste.”“In addition, while handling the TEPCO’s Fukushima nuclear
accident and its aftermath, the government and business operatorscame under heavy criticism for their inadequate information
sharing and lack of awareness about the need for communications
with the local communities concerned, resulting in a significant
decline in public trust in them.”
Unfortunately, the SEP merely repeats earlier assertions that “all is well” and does not propose any specificresponse to rebuild public confidence in the ongoing development of energy policy.
Information about specific plans for energy development, about the status of proposed new plants and about theperformance of existing units is not made available to the general public. Based on meetings with variousorganizations and individuals in Japan, this information is not generally available to legislators, agency staff or
nongovernmental organizations with specific interest in the subject. This situation stands in stark contrast to the
U.S. situation where detailed information about the status of proposed projects, costs and, importantly, theperformance of each unit that provides electricity to the grid is readily available27.
The broad access to detailed, hourly production and emission data that is available in the U.S. and the public
process of developing and refining proposals for energy policy allows all parties – businesses, local
governments, academics and NGOs – full access to the relevant information. This, in turn, provides for a morerobust and informed discussion of the issues and promotes better policy development. Recognizing thatproviding this level of access is not customary in Japan, it still must be observed that the lack of access to basic
information and transparency in the decision making process necessarily imposes a cost to Japan as it increases
the likelihood that the final policy will be less than optimal. Accordingly, and recognizing that this will be along term process, it is recommended that the GOJ take steps to liberalizing the publication of all relevant data
concerning the cost and performance of existing generating facilities and proposed energy options.

27. See, for example, www.ampd.epa.gov, http://www.eia.gov/todayinenergy/detail.cfm?id=15491, www.eia.gov/electricity/data/eia861/index.html,
2012 Coal Unit Characteristics, National Electric Energy Data System (NEEDS v4.10MATS) frame (EPA, December 2011) with additional
information EPA, 2013 as but a few of the dozen or more separate data sources for U.S. energy production.

- 24 -EVALATION OF ALTERNATIVES USING JAPAN’ S 3E+S FACTORSJapanese energy policy is based on the interplay of energy security, economic efficiency, environmental
impact and safety (3E+S). Disclosure of detailed facts relevant to the assessment of these factors is needed
before a final, informed evaluation can be made. Based on information available in Japan today, and a greater
pool of information available concerning costs and environmental issues, the following represents the author’s
best assessment of these issues. Assessment of energy security and safety are necessarily somewhat subjective.
The assessment of these issues that follows is based largely on consideration of the reasonable worst casescenario for each technology. The reader is invited to incorporate his or her own assessment of these risks inevaluating options.
Table 1 : 3E +S Factor Assessment
EnergySecurity

Economic
Efficiency

Environment

SafetyTransmission System Upgrade

High

High

High

High

Energy Efficiency

High

High

High

High

Distributed (roof top) Solar PowerHigh

MediumHigh

High

Utility Scale Solar Power

High

High

Good

High

Onshore Wind Power

High

High

Good

High

Offshore Wind Power

Medium28

MediumHigh

High

Small Scale Hydropower

High

Low

Good

High

Large Scale Hydropower

High

High

Medium29

Medium30

Small Scale GeothermalHigh

MediumHigh

High

Utility Scale Geothermal

High

High

Good

High

Coal (SCPC)

Poor31

MediumLow32

Medium33

Coal (IGCC)

Poor

MediumLow

MediumCoal (CCS)

Poor

Low

Poor

MediumNatural Gas (CCGT)

Poor

Low

Medium34

Good

NuclearPoor35Low

Unknown

Unknown

Oil

Poor

Poor

Medium/Low

MediumExisting Unit Efficiency Upgrade

Poor36High

Medium37

Good38

Technology

28. Offshore wind farms may face competing claims of national jurisdiction and interference with operation in times of international disagreements.
29. Large areas of habitat may be destroyed to create reservoirs.
30. Based on the low risk of dam failure.
31. Subject to international events that may increase prices and seaborne trade interference.
32. Based on environmental harm from mining operations, coal and ash storage, CO2, mercury and other emissions.
33. Based on the risk of mining accidents and deaths and failure of coal ash storage areas.
34. Based of CO2 and methane emissions and environmental damage from extraction activities.
35. Based on the price volatility of uranium fuel and the potential attractiveness of uranium fuel and waste as a terrorist target.
36. Based on the energy security of the underlying fuel.
37. Mitigates, but does not eliminate, the environmental impact of the underlying fuel.
38. Reduces the safety concerns of the underlying fuel.
- 25 -

CONCLUSION:
There are no technical or economic barriers that would preclude a rate of implementation of new renewableenergy of 2 percent of sales per year for a period of 10 years. This level of growth in renewable energy would be
sufficient to offset the increased use of fossil fuels that currently are used in lieu of nuclear generation. Given(1) the rapidly falling prices of renewable e energy, (2) the current high price for imported LNG, (3) the potential
for price and currency exchange volatility for nuclear and fossil fuels and (4) the likelihood of increased
maintenance costs associated with aging nuclear and fossil fuel-fired units, an aggressive program of support for
infrastructure needed to implement high levels of penetration of renewable energy would likely be the low cost
solution to Japan’s energy needs.
The SEP references a projection that renewables will provide 13.5 percent of Japan’s generation in 2020 and
20 percent in 2030. However, this outcome would be far too carbon intensive to slow the rate of damage fromclimate change. Importantly, the SEP does not establish any policy determination as to the amount or timing of
renewable generation that is to be achieved. Nor does the SEP provide any specific guidance to Japanese
program administrators, the legislature or the public as to what government measures, if any, will be taken to
ensure that this amount of renewable generation will occur.
There are no barriers to the economic development of large scale renewable energy in Japan, but there are
steps that must be taken if this is to occur. Kiko Network reports that over 15 GW of new coal generation isplanned over the next 6-12 years , while METI and JBIC actively promote the construction of new coal-fired
EGUs throughout Southeast Asia. At the same time, the GOJ is not moving with sufficient urgency to solve the
FIT, PPA and transmission problems that must be addressed to meet Japan’s need for clean, affordable andreliable energy. The reasons for delays in resolving these issues should be explained and resolved.
While the detailed design of a program to move forward would necessarily involve much more detailed analysis
than presented here, it seems that the key elements of the program would most likely include the following:(1) a realistic and ambitious renewable energy target and a comprehensive program that addresses generation,
storage and transmission needs as a whole;(2) a revised FIT, coupled with “take or pay” requirements under narrowly proscribed PPA terms;(3) to ensure the appropriate lower cost FIT that will support RE development targets, the GOJ might consider abidding process in which developers would bid a FIT price for up to the amount of RE scheduled for a given
year, with the requirement that the project be completed within a set time frame; Under this approach, thegovernment might establish a FIT of not more than 15¥/kWh39 for up to 5,000 MW of capacity (for example)
to be brought online no later than 2018. That FIT would be coupled with a PPA as described above thatprovided a secure revenue stream for 15 years. The amount of capacity and the maximum price for capacity
to be brought online by 2019 would be determined based on the results of the bidding process in the firstyear. Presumably, as Japanese developers and utilities gain experience the capacity would increase while themaximum allowed FIT would decrease.
(4) a manageable implementation schedule, nominally an increase in renewable energy generation of 2% of total
electricity sales per year;(5) substantial transmission system upgrades, funded by the ratepayers generally rather than individual
project developers;

39. As an example for solar power only. The PPA would be awarded to the lowest bidders.

- 26 -

(6) removal of artificial barriers to the development of RE, including revision of EIA project limits, developmentof model setback and noise requirements;(7) mandatory continuous emission monitoring, submission and public dissemination of hourly emission data
(SO2, NOx, PM2.5, Hg and CO2), gross and net electric output;(8) mandatory fuel efficiency improvements for existing fossil fuel-fired generation (without extending theuseful life of those units) and retirement of inefficient units as additional RE comes online;(9) CO2 emission limitations for new and existing coal-fired, gas-fired and oil-fired EGUs that force heat rate
improvements at existing units, environmental dispatch of those units (cleanest units first), retirement ofexisting fossil-fuel fired units in a prompt and orderly manner.
Such a program would likely prove to be a better solution to Japan’s 3E+S energy policy needs thancontinued investment in nuclear and new fossil fuel-fired generation.
The current SEP is lacking in objective, technical support and in transparency. There are many ways inwhich detailed cost, environmental and performance information can be acquired and assessed. One potential
path for a more transparent and inclusive policy development might be for the GOJ to establish a high level
panel comprised of members of the executive and legislative branches, industry and the environmental
community, supported by an independent unbiased technical consulting firm to develop and evaluate options.
The merits of each of these options for going forward might then be the subject of public discussion, with allparties having full access to the relevant facts, before final decision by the GOJ.
Perhaps the most important promise of the SEP, and what appears to be its greatest missed opportunity is
the following:“ Dependency on nuclear power is to be lowered to the extent possible byenergy saving and introducing renewable energy as well as improving theefficiency of thermal power generation.”
As revealed above, the SEP does not attempt to develop renewable energy and energy efficiency “to theextent possible” and, focusing only on new plants, makes no effort to improve the efficiency of the existing
thermal power generation fleet.

- 27 -

Author
Bruce C. Buckheit
Energy and Environment Consultant
Bruce Buckheit has been an independent consultant specializing in energy andenvironmental issues since 2004. He has worked with US agencies,
corporations, state organizations and environmental groups both in the US andabroad. Currently, he lends his expertise to technical and policy-related
studies on the performance of fossil fuel-fired electric generating unions andcompetitive alternatives. Prior to 2004 he was director of the Air Enforcement
Division of the U.S. Environmental Protection Agency, in which position heserved as the national program manager for U.S. Clean Air Act enforcement.
From 1984 to 1996, Mr. Buckheit served as senior counsel at the U.S.
Department of Justice’s Environmental Enforcement Section, where he
implemented the Federal enforcement response to a number of the mostsensitive and significant environmental enforcement issues then pending.

Author: Bruce C. Buckheit
Published by Kiko Network http://www.kikonet.org
Tokyo Office:
6F, Ichibancho-Murakami Bldg., 9-7, Ichibancho, Chiyoda-ku,
Tokyo 102-0082, JAPANTEL: +81-3-3263-9210 FAX: +81-3-3263-9463
E-mail: tokyo@kikonet.org
Kyoto Office:#305 Takakura Bldg. Takakura-dori, Shijo-agaru, Nakagyo-ku,
Kyoto 604-8124, JAPANTEL: +81-75-254-1011 FAX: +81-75-254-1012
E-mail: kyoto@kikonet.org