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The U.S. EPA has issued a revised Standard of Performance for Greenhouse Gas Emissions from New Electrical Generating Units, still subject to a comment and review period. The basic standards put forth are as follows:
The 850 mmBtu/hr is the thermal input and defines the size of the power plant. The 1,000-1,100 lb-CO2/MWh is the emission standard for that size. The actual rated output of the power plant is a function of the fuel type and its efficiency.
How the suggested standard translates into actual power plant sizes for the various fuel and power plant types can be seen in the Figure below. This is a summary of the key findings and assumptions embodied within the proposed ruling:
There is no difference between CO2 from a NGCC or coal power plant. It is just CO2.
The same Post Combustion capture technology can be applied to either NGCC or coal.
The de facto standard at the local Public Utility Commission (PUC) has been Coal-CCS vs. unabated NGCC for the last 5-years.
There are no new coal projects, other than those few subsidized Demo Projects mentioned, and no new projects in the planning stages.
We are not on the CCS “learning curve,” nor are we on the trajectory to achieving the 2°C/450 ppmv atmospheric CO2 target. It is not even clear if this is the target.
The ruling does not provide any mechanisms and platforms to establish a cost for CO2 emitted.
If coal had not proceeded with demo projects and therefore were to fall into the “unproven” category, would coal still have had to deploy with CCS?
And, why would anyone spend money to establish that NGCC-CCS is viable, when that would then set a new “proven” standard, obligating its use?
There is no mention of the actual climate change targets in the proposed ruling. There are references to climate change, but only in the abstract.
The BACT -Best Available Control Technology or BSER-Best System of Emission Reduction bases for this ruling are, by definition, a BAU-Business as Usual approaches, because they apply a commercial availability and readiness test to their implementation.
The term BSER was used to cover the combination of power plant and CCS, as applied to NGCC. This is an artificial point of difference between CCS applied to coal vs. gas to affect separate “readiness” outcomes.
Now the debate centers around whether Coal-CCS has been demonstrated enough, or even at all. The coal industry is suggesting, not.
And, the House Energy & Commerce Committee is investigating the EPA on that determination. And, the U.S. House of Representatives is also offering its own version of any ruling that seems to be supportive of the coal industry and with what appears to be an implementation in 2050, maybe. They ask that Best System of Emissions Reduction (BSER) be demonstrate within coal category as:
One continuous 12-month run of by each of (6) separate units at (6) separate locations, that collectively represent the operating characteristics of different US locations.
Each of which, must operate on a full commercial basis for an entire 12-month period.
And, that results from demonstration projects cannot be used in demonstrating the BSER. And, that there be a separate sub-category for (3) separate units operating on coal (lignite) with average heat content of 8,300 Btu/lb.
It is also clear that a couple of factions in this debate are using current low gas price to deflect criticism of the ruling itself.
Make no mistake; any root cause analysis on the negative impact on the coal industry will focus squarely on the EPA ruling, not the price of natural gas. Yes, the price of natural gas has had an enormous impact, but it has been that of an accelerant, not the root cause.
Four things are really clear to me: