University of San Diego

San Diego Journal of Climate & Energy Law


John H. Minan


The focus of this Article in on a subtler, but no less important, part of the climate change story involving energy and water. The focus in on the federal regulation of existing once-through-cooling (OTC) intake structures that are used by large steam electric-generating power plants. OTC, closed-cycle (CC) cooling, and dry-cooling (DC) each perform the same function, which is the removal of waste heat from the steam cycle after it has generated electricity.
The elimination of OTC systems would have a salutatory effect on the aquatic environment because fewer marine organisms would be destroyed by impingement and entrainment. But there are non-water quality impacts associated with realizing this benefit. The shift to other currently available cooling systems, which are not as economically efficient in generating electricity, will inevitably result in higher electricity rates. Given the struggling economy shifting this added cost to consumers is not likely to be embraced with enthusiasm.