carbon capture and storage

Why Courts Should Repeal EPA’s ‘Carbon Pollution’ Standard (and why you should care)

by Marlo Lewis on November 19, 2012

in Features

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Note: A nearly identical version of this column appeared last week in Forbes Online. I am reposting it here with many additional hyperlinks so that readers may more easily access the evidence supporting my conclusions.

The November 2012 elections ensure that President Obama’s war on coal will continue for at least two more years. The administration’s preferred M.O. has been for the EPA to ‘enact’ anti-coal policies that Congress would reject if such measures were introduced as legislation and put to a vote. Had Gov. Romney won the presidential race and the GOP gained control of the Senate, affordable energy advocates could now go on offense and pursue a legislative strategy to roll back various EPA global warming regulations, air pollution regulations, and restrictions on mountaintop mining. But Romney lost and Democrats gained two Senate seats.

Consequently, defenders of free-market energy are stuck playing defense and their main weapon now is litigation. This is a hard slog because courts usually defer to agency interpretations of the statutes they administer. But sometimes petitioners win. In August, the U.S. Court of Appeals struck down the EPA’s Cross State Air Pollution Rule (CSAPR), a regulation chiefly targeting coal-fired power plants. The Court found that the CSAPR exceeded the agency’s statutory authority. Similarly, in March, the Court ruled that the EPA exceeded its authority when it revoked a Clean Water Act permit for Arch Coal’s Spruce Mine No. 1 in Logan County, West Virginia.

A key litigation target in 2013 is EPA’s proposal to establish greenhouse gas (GHG) “new source performance standards” (NSPS) for power plants. This so-called carbon pollution standard is not based on policy-neutral health or scientific criteria. Rather, the EPA contrived the standard so that commercially-viable coal plants cannot meet it. The rule effectively bans investment in new coal generation.

We Can Win This One

Prospects for overturning the rule are good for three main reasons. [click to continue…]

EPA’s Carbon Pollution Standard — One Step Closer to Policy Disaster

by Marlo Lewis on June 25, 2012

in Features

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Today (June 25th) is the deadline for submitting comments on the EPA’s proposed Carbon Pollution Standard Rule, which will establish first-ever New Source Performance Standards (NSPS) for carbon dioxide (CO2) emissions from fossil-fuel electric generating units.

The proposed standard is 1,000 lbs of CO2 per megawatt hour (MWh). The EPA claims that 95% of all new natural gas combined cycle power plants can meet the standard — maybe, maybe not. One thing is clear — no conventional coal power plant can meet the standard. Even today’s most efficient coal power plants emit 1,800 lbs CO2/MWh on average.

A coal power plant equipped with carbon capture and storage (CCS) technology could meet the standard, but the EPA acknowledges that  CCS is prohibitive, raising the cost of generating electricity by as much as 80%.

So what the proposal is really telling the electric utility industry is this: If you want to build a new coal-fired power plant, you’ll have to build a natural gas combined cycle plant instead. Not surprising given President Obama’s longstanding ambition to “bankrupt” anyone who builds a new coal power plant.

In a comment letter submitted today on behalf of the Competitive Enterprise Institute, I recommend that the EPA withdraw the proposed regulation for the following reasons: [click to continue…]

EPA’s “Carbon Pollution” Standard for Power Plants: Four Ways Weird

by Marlo Lewis on March 28, 2012

in Blog, Features

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Yesterday, EPA proposed its first-ever “carbon pollution standard rule” for power plants. The rule would establish a new source performance standard (NSPS) for carbon dioxide (CO2) emissions from fossil-fuel electric generating units (EGUs). The proposed standard is an emission rate of 1,000 lbs CO2 per megawatt hour. About 95% of all natural gas combined cycle (NGCC) power plants already meet the standard (p. 115). No existing coal power plants do. Even today’s most efficient coal plants emit, on average, 1,800 lbs CO2/MWh (p. 134). EPA is effectively banning investment in new coal electric generation.

Like the rest of EPA’s greenhouse agenda, the proposed rule is an affront to the Constitution’s separation of powers. Congress never voted to prohibit the construction of new coal power plants. Indeed, Congress declined to pass less restrictive limits on coal electric generation when Senate leaders pulled the plug on cap-and-trade. Congress should reassert its constitutional authority, overturn the rule, and rein in this rogue agency. [click to continue…]

Fantasizing about a low-carbon future

by Myron Ebell on September 15, 2009

in Blog

I attended an excellent briefing  today on “Creating a low-carbon future” by Michael Howard of the Electric Power Research Institute (EPRI).  The event  was hosted by the U. S. Energy Association and its executive director, Barry Worthington.   EPRI has done a lot of work on how the electricity sector could meet the greenhouse gas emissions target in the Waxman-Markey energy-rationing bill.  That target is economy-wide emissions 83% below 2005 levels by 2050.

Howard said that EPRI wanted to identify a strategy by which the electric sector could be de-carbonized affordably.  Here’s the background and how EPRI would do it:

The decisions made today and in the next few years will shape electric generation in 2050, so we have to make the right decisions starting now.  Electricity generation accounts for about one-third of the 2005 U. S. total of six billion metric tons of carbon dioxide emissions.  Electric rates in constant dollars have been remarkably flat for the past forty years.

EPRI has identified two paths to meeting the 83% reduction target.  The first is by deploying a full portfolio of energy sources.  A full portfolio would most notably include expanded nuclear power and widespread carbon capture and storage for coal and natural gas.  The second is by deploying a limited portfolio of sources that would exclude nuclear and carbon capture and storage.

What is most apparent in EPRI’s modeling is that the limited portfolio approach would end the use of coal completely by 2030.  Renewables would go up, but the biggest increases would be in the use of natural gas.  The result is that electricity would become very expensive, with rates tripling by 2050 in constant dollars.  In addition, we would be forced to use much less electricity in order to meet the emissions reduction targets.

The full portfolio scenario projects that most of the cuts would be made by building new nuclear power plants and new coal plants that capture and store 90% of the carbon dioxide emissions produced.  Natural gas use would go down considerably.  EPRI projects that electric rates would not quite double by 2050 were the full portfolio approach pursued.  Enforced reductions in use would only be about half as severe under the full portfolio compared to the limited portfolio.

The full portfolio scenario sounds very nice, but it’s fantasy.  It has almost nothing to do with the real world.  What EPRI (understandably) does not include in their models are the increasing political, regulatory, and legal obstacles to building new power plants.  Even if carbon capture and storage technology becomes commercially viable by 2020 (which is highly unlikely), it will take decades to permit and build more than a handful of coal plants that capture the carbon dioxide, the pipelines to transport it, and the underground pockets to store it.   Permitting delays will put pipeline siting and construction years behind schedule.  Lawsuits will be filed claiming that pressurized CO2 is too dangerous to be allowed.   Similarly, a few new nuclear power plants may be built in the next twenty years, but building a lot of new plants will take decades to overcome the permitting obstructions.

These obstacles do not apply only to coal and nuclear plants.  Proposed wind and solar energy projects are being blocked and delayed all around the country.  Bobby Kennedy, jnr., is leading the campaign to block a big wind farm off Cape Cod, where his family own valuable, scenic vacation property.  At the same time, Kennedy has lashed out at local environmental pressure groups at the other end of the country that are trying to block a big solar energy development in the Mojave Desert that he has invested in.  Even if both projects eventually get built, they are being delayed for years.  This is a problem that the environmental pressure groups have helped to create and don’t want to admit exists.  It means that the limited portfolio approach modeled by EPRI is fantasy, too.

One of the problems with relying on EPRI’s or any of the economic models to predict the costs of reducing greenhouse gas emissions is that they assume that political decisions will be made in a rational, orderly way that will allow economic decisions to be made in an efficient way.  The Waxman-Markey energy rationing bill (H. R. 2454) is just the latest disproof of this assumption.  The bill creates a cap-and-trade program to reduce emissions and then adds several hundred other programs to pay off individual special interests.  Nearly all these programs get in the way of the efficient working of cap-and-trade.  They will raise the costs of making mandatory reductions beyond what any model can predict.