Picture in your mind a house of cards or a row of dominoes. Pull out the base card and the structure collapses. Knock over the first domino and the rest fall down. Either image is a suitable metaphor for President Obama’s climate policy agenda.
EPA’s so-called Carbon Pollution Standards rule for new fossil-fuel power plants is the first domino in the row, the base of a multi-tiered greenhouse of cards.
The rule would establish “partial” carbon capture and storage (CCS) as the “adequately-demonstrated” (commercially-viable) “best system of emission reduction” (BSER) for new coal-fired power plants.
The jerry-built logic works like this.
- The Carbon Pollution rule is the legal prerequisite for EPA’s carbon dioxide (CO2) performance standards for existing power plants, the so-called Clean Power Plan.
- The Clean Power Plan, in turn, is the core component of the President’s emission-reduction pledge — the U.S. Government’s “Intended Nationally Determined Contribution” or INDC — in UN-sponsored negotiations aimed at adopting a new climate treaty at the December COP 21 conference in Paris.
- Finally, the President hopes the new climate pact, which he will not submit to the Senate for a vote on ratification, will focus international pressure on the next president and Congress to honor the U.S. INDC, thereby locking in the Carbon Pollution and Clean Power rules as legacy policies.
Each link in the chain has severe structural weaknesses. Using a non-ratified treaty to dictate U.S. domestic policy raises profound separation of powers concerns. The Clean Power Plan is unlawful on at least 10 separate counts. Evidence mounts that CCS technology is not adequately demonstrated because it is unaffordable absent lavish subsidies — hence the Carbon Pollution rule would not survive judicial review.
The point I want to emphasize in today’s post is that in actual commercial practice, CCS would increase net CO2 emissions. Thus what EPA is proposing is not even a system of emission reduction, much less the “best system of emission reduction” required by the Clean Air Act.
To recap, CCS, even when subsidized, is generally not economical unless coal power plants can sell the captured CO2 to drilling companies for use in “enhanced oil recovery” (EOR). Injecting millions of tons of CO2 into older wells facilitates extraction of “tertiary” oil in two ways. The CO2 mixes with the oil, reducing its viscosity, and builds pressure within the field, pushing more oil to the well bore.
In a 2011 report, DOE’s National Energy Technology Laboratory (NETL) estimated that injecting 20 billion tons of CO2 underground for EOR would increase U.S. oil production by 67 billion barrels. When those barrels are combusted, however, they emit CO2. So the obvious question — which EPA’s Carbon Pollution rule never addresses — is what is the net change in emissions when CCS and EOR are combined.
According to EPA data, combusting one barrel of oil emits, on average, 0.43 metric tons of CO2. Plugging that conversion factor into NETL’s analysis, injection of 20 billion metric tons of CO2 produces 67 billion barrels of oil that, when combusted, emit 28.81 billion metric tons of CO2. In other words, CCS combined with EOR emits 1.41 tons of CO2 for every ton injected underground.
A colleague recently told me this couldn’t possibly be true, so I did some further checking. Turns out, NETL also published a primer on EOR. It summarizes the emissions data of a potential CCS-EOR operation:
For example, a study by Montana Tech University found that CO2 flooding of Montana’s Elm Coulee and Cedar Creek oil fields could result in the recovery of 666 million barrels of incremental oil and the storage of 2.1 trillion cubic feet (109 million metric tons) of CO2. All of the CO2 required for the flood could be supplied by a nearby, coal-fired power plant, and would equate to 7 years of the plant’s CO2 emissions.
Again, using EPA’s emission conversion factor, when combusted, the 666 million barrels of oil recovered would emit 286 million metric tons of CO2 — more than twice the quantity (109 million metric tons) injected and sequestered. That implies an even bigger net increase than NETL’s 2011 report indicates — about 2.6 tons of CO2 emitted for every ton stored underground.
Note: I intend no criticism of EOR, a potentially profitable means to expand global petroleum supply, benefitting consumers everywhere. My beef is with EPA’s Carbon Pollution rule and the far more aggressive domestic and international climate policy initiatives it ostensibly underpins.
To sum up, CCS is only remotely economical (“demonstrated”) when combined with EOR, but the combination increases net CO2 emissions compared to a conventional coal power plant. In real-world commercial applications, CCS cannot be a “best system of emission reduction” because it increases net CO2 emissions. The Carbon Pollution rule is fatally flawed, imperiling both the Clean Power Plan and, thus, the administration’s INDC in the COP 21 negotiations.