Ongoing litigation over EPA rules raises compliance risks and costs. North Carolina utilities, however, benefited from the state’s forward thinking.
The Capture-Committed Power Plant
Moving coal forward requires a clear path to CCS.
costs. At a minimum, it means leaving space for the capture equipment and access to potential underground CO 2 storage.
One issue for plant developers is pre-investment, that is, the amount of money that can be spent during the planning and construction of the original plant without capture. For the most part, this pre-investment involves over-sizing equipment and adding more stringent emission controls than originally needed. Analyses show that only relatively low levels of pre-investment financially are viable, but this depends upon the expectations of the cost of CO 2 emissions ( e.g., in an emissions-trading program) and how soon CCS would need to be implemented. 6 Expectations for higher costs of CO 2 emissions and nearer-term needs increase the value of pre-investment.
A number of studies have considered the modifications necessary to make a plant capture ready. Several definitions of “capture-ready” power plants have been proposed and these vary in specificity. Perhaps the best known definition is given in a study by the IEA Greenhouse Gas R&D Programme which, along with detailed design studies of several types of plants, developed a preliminary definition of capture readiness as a starting point for discussion: 7
A CO 2 capture-ready power plant is a plant which can include CO 2 capture when the necessary regulatory or economic drivers are in place. The aim of building plants that are capture ready is to avoid the risk of “stranded assets” or “carbon lock in.”
Developers of capture-ready plants should take responsibility for ensuring that all known factors in their control that would prevent installation and operation of CO 2 capture have been eliminated. These might include:
• A study of options for CO 2 capture retrofit and potential pre-investments;
• Inclusion of sufficient space and access for the additional plant that would be required; and
• Identification of a reasonable route to CO 2 storage.
Competent authorities involved in permitting power plants should be provided with sufficient information to judge whether the developer has met these criteria.
The questions of exactly what criteria should be met and what constitutes “sufficient information” remains open.
Readiness Isn’t Enough
Claims of the capture readiness of proposed new coal-fired power plants have met considerable skepticism. Many observers see capture readiness as a delaying tactic. They question whether the implied commitment to capture CO 2 is real, or see capture- readiness proposals as evidence that CCS is not a viable option. In particular, they assert that plant developers make no clear commitment actually to install CCS at a specified later date, that financing of the CCS retrofit is not certain, and that what makes a plant capture ready may not be much at all.
Some argue that power plants should be required to implement storage immediately and that enough is already known to implement it. 8 They argue that CCS is ready, but this argument is based primarily on an assessment of only the storage component of CCS. 9 That argument, moreover, does nothing to address the very real technical, regulatory and financial hurdles currently facing power generators considering CCS.