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.
spent? What if actual costs are different from estimates? What should be done with the funds if they are forfeited? How should non-financial assets be addressed? The answers may differ from state to state or even from plant to plant.
Third, industry and government researchers must conduct further work in the public domain to define the technical aspects of capture readiness in steam-cycle plants. It would be most helpful for plant designers to be able to create capture-committed designs with the flexibility to implement a wide range of the potential future capture options. Most of the work on capture readiness so far has focused on oxyfiring and amine post-combustion capture. Other post-combustion options must be explored, such as ammonia. Plants with cyclone systems are well suited for low-rank coals and may require somewhat different considerations for oxyfiring than pulverized coal plants. Some plant developers also might be considering fluidized bed combustion, which has the advantage of high fuel flexibility and the potential environmental benefit of being able to co-fire a high percentage of biomass. Yet, very little work has been done to address the retrofit of capture in either cyclone boiler or fluidized-bed combustion power plants. Cyclone boilers and fluidized-bed combustion are important where low-rank coals, biomass or waste fuels are to be used. Designs that minimize downtime during construction of the capture equipment also would be useful. Ideal designs would have connections to the prospective capture equipment already in place with all that is required being, in essence, to open the valves and test the system.
Fourth, lawmakers must ensure that plants with CCS receive financial benefits of any emissions-trading systems commensurate with their CO 2 reductions. Emissions-trading systems have been designed by states and regions and have been proposed in the U.S. Congress. Plants that capture CO 2 shouldn’t need to buy allowances for CO 2 that is stored securely and verifiably.
Fifth, the industry must continue its progress in developing commercial CCS technologies. This progress is the sine qua non of assuring that the full benefits of capture commitments are realized by both the public and the plant developer. Research, development and demonstration of CCS must continue and accelerate to improve the effectiveness, efficiency and cost of CCS. Most important is the implementation of a fleet of multiple full-scale integrated CCS demonstration power plants that demonstrate a range of capture technologies and storage in diverse geologic reservoirs. 14
Finally, policymakers will need to develop a complete legal and regulatory framework for CCS. Many issues must be addressed, and to a large extent, these require state actions. The Interstate Oil and Gas Compact Commission has developed a set of model regulations for CCS that can serve as a starting point for state action. 15 The most significant federal regulatory responsibility with regard to CCS is the Environmental Protection Agency’s (EPA) Underground Injection Control (UIC) program, which governs underground injection wells. EPA has proposed UIC regulations that would apply to CCS and these can be expected at some point to move into final status. 16
Coal-fired power generation will continue, even