Hearings on S. 556, the Clean Power Act:
U.S. Senate Committee on Environment & Public Works
November 15, 2001
Testimony of David G. Hawkins
Director, NRDC Climate Center
Natural Resources Defense Council
Mr. Chairman and members of the Committee, thank you for providing the Natural Resources Defense Council (NRDC) the opportunity to present its views on S.556, the Clean Power Act of 2001. The Natural Resources Defense Council is a national, non-profit organization of scientists, lawyers, and environmental specialists, dedicated to protecting public health and the environment. Founded in 1970, NRDC serves more than 500,000 members from offices in New York, Washington, Los Angeles, and San Francisco.
NRDC strongly supports enactment of S.556; the comprehensive clean-up program for electric power plants contained in the bill is vital to reduce the health and environmental toll from the continuing air pollution released by these plants.
Electricity has brought us an unequalled quality of life and a thriving economy but it continues to be produced in ways that also bring us large and unnecessary harm to human health and to the environment. The electric generating sector remains the largest single polluting activity in the United States. Electric generators are responsible for two-thirds of America’s sulfur dioxide pollution, nearly one-third of its nitrogen oxides, forty percent of carbon dioxide and more than one-third of remaining mercury emissions.
Together these “four horsemen” of power plant pollution cause tens of thousands of premature deaths each year and hundreds of thousands of respiratory illness cases. They also kill lakes and threaten forests, contaminate fish, and fill the skies over national parks with haze. Carbon dioxide from the electric generating industry traps heat in the atmosphere, leading to disruption of the climate that we all depend on to maintain life as we know it on this planet.
There is broad recognition that the time has come to reduce pollution from this industry. We have the means to do so and the job is affordable. Indeed, when pollution caps are integrated with expanded reliance on energy efficiency and renewable energy sources, as called for in S.556, we can save consumers money while reducing the damage electricity production does to health and the environment.
Opponents of S.556 have raised a number of issues but I’d like to focus in this testimony on two topics: the bill’s requirements for control of the global warming pollutant, carbon dioxide (CO2); and issues relating to control requirements for western states.
S.556 calls for the electric generating sector to return its CO2 emissions to 1990 levels. The power industry often argues for voluntary approaches to CO2 control, but it is now abundantly clear that voluntary measures alone do not work. In fact, despite widespread participation in the voluntary “Climate Challenge” program, CO2 from electric power plants grew over the PAST decade by a rate triple the growth rate of other energy consuming sectors: 26.5 percent compared to 8.9 percent. This huge increase occurred even while the industry was claiming to have made millions of tons of CO2 “reductions” under the Climate Challenge program’s creative but ineffective accounting rules. . I am attaching NRDC’s recent report “Reported ‘Reductions,’ Rising Emissions” for the record.
It is not surprising that voluntary programs have failed to reduce CO2 pollution. As long as CO2 can be dumped for free into the air, competitive pressures will reward behavior that increases this pollution.
S.556 would cap CO2 from the power sector at its 1990 levels—a target consistent with our pledge in the 1992 Framework Convention on Climate Change signed by the first President Bush and ratified by the Senate. It should be noted that this is not the level specified in the 1997 Kyoto Protocol, which the current Administration has rejected. But the current Administration apparently opposes capping CO2 at any level. In testimony on November 1 of this year, EPA Assistant Administrator Holmstead set forth the Administration’s reasons for its opposition to any requirement to control CO2 from power plants. The Administration claims that CO2 controls will cost consumers too much and make generation too dependent on natural gas. The Administration also asserts that decisions to control CO2 should be made as part of broad climate change policy.
Contrary to the Administration’s claims, S.556 will save consumers money, will reduce growth in consumption of natural gas and will lay the groundwork for broader efforts to combat climate change.
The Costs of Delay
The Administration states that it takes the issue of climate change very seriously. But its opposition to controlling power plant CO2 is a serious mistake. This past weekend, the world’s other industrialized countries agreed to take steps to significantly limit global warming pollution over the coming decade. In response, the President’s spokesman is quoted as saying the President “agrees with the need to reduce greenhouse gas emissions. His Cabinet review is under way, to determine a way that can be done without forcing America into a deep recession.”
The fact is that the October 31 analysis of S.556 submitted by Mr. Holmstead for the Administration demonstrates that controlling CO2 from power plants will help the economy, not harm it. That analysis concludes that US gross domestic product would be higher under S.556, not lower.
To take climate change seriously, one must look at the costs of delay in taking action. The assumption of many is that by delaying action to limit global warming pollution we will reduce costs. That assumption is wrong and ignores the nature of the global warming problem. Today’s atmospheric concentrations of CO2 are 30 percent above pre-industrial levels, higher than they have been in over 400,000 years. They have reached that level in a geological blink of an eye due to our burning of fossil fuels. By burning these fuels we are returning to the atmosphere heat-trapping gases that were isolated over a period of about 75 million years. The speed at which we are reversing the earth’s geologic history is astounding: each year we put back into the atmosphere an amount of CO2 that took 100,000 years to store in fossil fuels. CO2 stays in the atmosphere hundreds of years once it is released, so each year we allow CO2 emissions to grow, we are committing many generations to the consequences of the resulting change in climate.
The only way to limit the extent of the climate change we inflict on future generations and ourselves is to limit, or stabilize, atmospheric CO2 concentrations and to do that we must act to reduce emissions. The longer we wait to start, the more expensive we make it to achieve any particular stabilization target. To stabilize CO2 levels in the atmosphere, we must limit the total cumulative tons of CO2 we release. For example, to limit the atmospheric buildup of CO2 to a level about 60 percent higher than pre-industrial levels (today it’s 30 percent higher), cumulative global manmade carbon emissions up to the year 2100 must be kept below 950 billion metric tons. We have already released about one-third of this budget. But the real problem lies immediately ahead: at current emission rates we will consume half of the remaining budget in less than 30 years.
Imagine you are on a supertanker so close to a reef that you will cover half the remaining distance in the next 20 minutes. There is time to avoid the reef only if the tanker alters course immediately. Our economy can grow without increasing carbon emissions but only if Congress acts now to signal the market that these emissions can no longer be dumped for free. Unless we act now to lower the business as usual growth in CO2 emissions, we will eliminate our ability to stabilize concentrations at more protective levels or force later action that is wrenching and expensive, requiring extremely rapid reductions in these gases.
The other feature of the climate problem is that energy systems cannot turn on a dime. While some may use this fact to argue against S.556, the opposite is true. To establish the market signals needed to promote cleaner and smarter energy technologies we need to adopt policies now to limit CO2 emissions. As long CO2 can be dumped for free, the market will discourage the investments needed to modernize our energy technologies.
Let me give an example of how the status quo distorts decisions away from climate friendly actions. In the US today, there is much talk about the need for energy security. While energy efficiency will give us the largest, most secure additional domestic supply, investments in efficiency continue to be undervalued, in large part because there is no value assigned to the pollution that efficiency prevents, particularly carbon emissions. As I discuss below, investments in energy efficiency make it possible to implement S.556 while saving consumers money. But it is unlikely the market will spur adequate efficiency programs as long as carbon emissions are ignored in calculating the value of efficiency improvements.
Energy production choices are also distorted. For example, there are potentially more than 2 billion barrels of domestic oil in current producing fields that could be developed using enhanced oil recovery (EOR) techniques. In today’s EOR operations companies are injecting 20 million tons a year of CO2 into depleting wells to increase production. But nearly all that injected CO2 comes not from power plants or other industrial sources. Rather, the CO2 is pulled out of natural reservoirs and piped hundreds of miles to the oil fields.
EOR operators enjoy a 15 percent tax credit for expenses, including the cost of the CO2 they buy. So today American taxpayers are subsidizing businesses to pull new CO2 out of the ground when that CO2 could be supplied instead by the nation’s huge combustion sources – while at the same time keeping it out of the atmosphere. But as long as CO2 can be freely dumped into the air, the economics favor pulling CO2 out of the ground. And it gets worse. Much more oil could be produced through EOR but for the “shortage” in CO2 for injection. Aging coal-fired power plants could be repowered with integrated coal-gasification combined cycle technology to provide that CO2 while making electricity at competitive prices. But when it costs electric generators nothing to dump their CO2 in the air, they have no incentive to invest in capture equipment. Rather, under the status quo, investments are being made instead in developing new CO2 reservoirs to meet demand by pulling more CO2 from the earth rather than capturing what we are releasing to the atmosphere. Nowhere is this more striking than in Arizona, where Tucson Electric is applying for permits to build two new coal-fired units at Springerville while Ridgeway Petroleum is planning to extract CO2 from a natural reservoir that is literally underneath the power plant.
Adopting the CO2 caps in S.556 would change the incentives and promote investments in efficiency, renewable energy and CO2 capture and avoidance measures. But the Administration says it would cost consumers too much, with Mr. Holmstead’s testimony claiming that the bill would cause a 30-50 percent increase in electricity prices. This Committee heard similar claims in the 1980’s when industry and the Reagan Administration claimed that enacting acid rain controls would raise electric rates by 30 percent or more. Of course, nothing like that happened, nor will it under S.556.
Two assumptions affect forecasted costs of S.556 more than any others: what is the predicted growth in electricity and natural gas demand, and will Congress adopt revenue recycling provisions to prevent windfall profits to electric generating companies? One can calculate high costs for controlling carbon emissions only if one assumes little is done to improve energy efficiency and use of renewable energy and if one assumes that Congress will let electric generators retain $50-100 billion in windfall profits. Mr. Holmstead’s testimony makes both these assumptions in predicting large price rises for electricity.
However, according to the full EPA study of S.556, U.S. gross domestic product would actually be higher under S.556 than under business-as-usual as a result of the stimulus-producing programs for energy efficiency and renewable energy promoted by the bill. As for natural gas dependence, the S.556 program of efficiency and renewable energy would actually reduce natural gas use for electricity generation compared to the Administration's energy plan. With the S.556 emission controls and advanced energy efficiency and renewable energy programs implemented, expenditures on electricity generation would actually be $3 billion per year less in 2015 than under the Administration's energy plan.
EPA’s underlying report documents the power of the integrated strategy of emission caps, improved efficiency, and greater renewable energy sources that is called for in S.556. By improving efficiency and increasing the share of renewable energy sources, we can reduce the rate of growth in demand for electricity and for natural gas, thereby allowing the emission reductions required by S.556 to be achieved without diminishing economic growth. The tools to accomplish this smarter energy future have been documented in the November 2000 report by the Department of Energy’s principle research labs. “Scenarios for a Clean Energy Future” shows that an integrated program of efficiency and renewable energy policies can save consumers money and help achieve reduced emissions, including CO2 emissions at much lower costs.
The Energy Information Administration (EIA) has criticized the Clean Energy Futures (CEF) policies as not being realistically achievable. But EIA has not supported its criticism with any real analysis – rather EIA merely asserts that this rapid deployment of energy efficiency and renewable power technology is unlikely It is important to understand the relative competencies of these two different institutions within DOE. EIA’s expertise is in retrospective analysis of energy market statistics, so it is not surprising that its projections forward are heavily colored by its familiarity with the past trends. In contrast, the National Energy Labs that prepared the CEF report are expert in the engineering and economics of conventional and advanced energy efficiency and renewable energy technologies. The CEF experts have prepared a rebuttal to EIA’s criticism that adds further support to the CEF report’s findings. I have attached this to my testimony and ask that it be included in the record.
An examination of the CEF report demonstrates the reasonableness of the National Energy Labs’ view that we have a large untapped potential to improve efficiency and save money. The measures called for in the CEF report are not dream technologies, waiting to be invented; they are common-sense initiatives designed to increase the use of technologies that already exist. The CEF measures include improved appliance efficiency, through labeling, standards, and financial incentive programs. They include similar measures for buildings, calling for less wasteful heating, cooling and lighting systems and weatherization and rebate programs to reduce gas and electric use in existing buildings.
EIA claims the CEF’s projected rate of deployment for these technologies is unreasonable. But in only six months, Californians were able to reduce their electricity consumption by 6% during the summer of 2001, with no deprivation. This experience should encourage us not to sell short our ability to be smarter about energy use, given the appropriate policy support.
The Administration asserts the goal of its energy plan is to reduce demand and greenhouse gas emissions to levels well below EIA’s business as usual (BAU) forecasts. These are laudable goals but the Administration’s use of BAU forecasts to critique S.556 is inconsistent with those goals. The Administration needs to frame specific policies to achieve appropriately ambitious goals for energy efficiency and renewable energy. When it does so, it will conclude, as DOE’s experts have, that S.556 will help, not hurt consumers.
When policies to promote efficiency and renewables are combined with emission caps the cost of meeting S.556’s pollution targets is dramatically reduced compared to BAU assumptions. Under BAU, EPA calculates S.556 would increase costs of electric generation by $17 billion per year in 2015; with very modest efficiency efforts the cost drops to under $13 billion; with the CEF moderate policies the costs drop to $500 million; and with the CEF advanced policies called for in S.556 there is a savings of $3 billion a year in electric generation costs. We can clean up power plants and save consumers money through smart policies to reduce waste and increase renewable energy supplies.
EPA’s analysis makes another unstated assumption that drives up costs for consumers. Mr. Holmstead blamed S.556 for these consumer cost increases but the real blame lies with the policy chosen by EPA. Even though EPA’s study shows changes in generating costs under S.556 range from a maximum increase of $17 billion per year to a savings of $3 billion per year, the study calculates consumers’ bills would go up by $50 to $100 billion per year. EPA reaches this conclusion by assuming that the law you will enact will let generators retain windfall profits from the value of carbon permits under a cap and trade program. EPA’s approach assumes a large transfer of wealth from consumers to shareholders of generating companies, by grandfathering the value of carbon permits to the polluters themselves.
S.556 does not call for any such result. With more sensible approaches to carbon allowance allocation than the Administration assumes, households will have lower net costs under S.556. There are a number of approaches to deny windfall profits to generators and recycle revenue to consumers and S.556 encourages EPA to adopt such approaches in designing the cap and trade program for carbon.
The Administration also claims that S.556 will endanger energy security by requiring too much natural gas for electric generation. But large increases in natural gas use do not occur if the integrated CEF efficiency and renewable policies called for in S.556 are implemented. Under either the moderate or advanced CEF policy programs, EPA’s study confirms that natural gas use in electric generators will be less than under BAU growth with no emission controls. There is no reason to oppose limits on carbon pollution in order to avoid excessive dependence on natural gas or any other single fuel for electricity generation. Smart policies that harness the largely untapped potential of efficiency and renewable energy do a better job of promoting fuel diversity and attack the problem of global warming at the same time.
The Role of Coal
Mr. Holmstead states the Administration’s goal of preserving our ability to use coal as a major fuel source for electricity. It bears emphasis that under all analyses of S.556, coal would continue to provide the largest single share of fuel input for electricity. NRDC is neither for nor against an expanded role for coal or any other fuel for its own sake. We do believe that the public health and environmental harm caused by coal has not been adequately addressed, including the harm from global warming. But we do not agree that refusing to address global warming will help keep coal viable. To the contrary, if Congress fails to adopt requirements to limit CO2, it will send a signal to the market that delay in perfecting techniques to manage carbon from coal is a smarter course than moving forward with investments to modernize coal use.
Our nation and others do face a challenge in addressing the future role for coal in the carbon-constrained world of the future. But the way to meet that challenge is not to deny the need for action now to limit global warming pollution. Contrary to some claims, there is technology to separate and capture CO2 from coal and other fuels. Like many technologies, current processes were not developed for pollution control purposes and are not optimized for that purpose today.
There is reason for optimism that we can both fight global warming and continue to rely on coal as a major fuel in the decades ahead. Systems that separate CO2 from fossil fuels, both in pre-combustion and post-combustion configurations, have been commercially demonstrated. For new applications, vendors are offering quotes for IGCC plants with only modest additional costs for carbon capture. Current systems to capture CO2 from existing units have high economic and energy penalties. That is not surprising since there has been almost no market reason to invest resources to improve these systems.
On the storage side of the carbon management issue, as I mentioned above, commercial operators are currently injecting large amounts of CO2 into oil fields for enhanced oil recovery. But, as mentioned, nearly all of that CO2 comes not from fossil-fired plants, but from natural underground CO2 reservoirs. The pipelines that carry CO2 from these reservoirs in Utah and New Mexico run close to much larger man-made sources of CO2 at coal-fired power plants but as long as those plants can dump their CO2 for free, investors will not turn to those sources to meet the growing demand for CO2 for oil recovery. Coal industry supporters should be looking at every ton of CO2 that is pulled out of natural reservoirs as a lost market opportunity for plants that use coal but they appear to be stuck in the position of delaying policies that would stimulate use of their CO2 in this market.
Other markets, such as enhanced coal bed methane recovery, are likely to emerge for captured CO2 , if S.556 is enacted. Enhanced coal bed methane involves injecting CO2 into coal beds to drive off methane, which we know as natural gas. There is a thriving conventional coal bed methane industry in Wyoming and Montana today. Unfortunately, short-sighted operators have chosen to dump massive amounts of production water on the ground rather than managing these wastes responsibly but these problems can and should be solved if we want to use this resource. Other coal seams suitable for enhanced coal bed methane are located in eastern coal provinces.
As our country struggles with concerns about energy security, increased focus will be placed on developing alternatives to petroleum for transportation sources. Coal can play a role here as a feedstock for production of liquid fuels and hydrogen to fuel transportation systems. But this will not happen if the plants to produce such fuels are not designed to capture and safely store the CO2 from coal. It will not happen because of environmental opposition and because of investor uncertainty of the viability of such plants in a world where carbon emissions are likely to be regulated.
So, it is hard to see that the status quo is good for coal’s future. Most new electric generating plants are being built to use gas, not coal. Potential markets for CO2 from coal-fired plants to recover oil and coal bed methane are being ignored. New markets for transportation fuels from coal gasification plants are not being developed. This state of affairs is likely to continue until Congress takes steps to limit carbon emissions and signal the market that deploying advanced coal systems makes good business sense.
POWER PLANT POLLUTION IN THE WEST
Some have argued that the requirements for power plant clean-up for plants located in western states should not be as strict as for the rest of the country. NRDC disagrees with this argument. Air pollution from electric generation in the west continues to contribute to adverse health and environmental effects. There is no compelling case that control of pollution from these plants is uniquely difficult or expensive to achieve.
On good days the air quality in the western United States is a resource that is unparalleled in the industrialized world. Visitors from around the world come to marvel at the landscapes of the west and the crystal blue skies that are still present in many places on many days. Great cities in the west have grown in part due to the attraction of clean air and the quality of life provided by unspoiled surroundings.
But air pollution has come to the west as well. Sulfur dioxide pollution is acknowledged to be a major contributor, particularly in the summer, to regional haze that degrades visibility. SO2 also leads to elevated fine particle concentrations in metropolitan areas of the west, contributing to significant health threats; and SO2 damages sensitive species and other air quality related values in parks and wilderness areas.
To address regional haze, the Western Regional Air Partnership (WRAP) has recommended a schedule for western regional SO2 reductions. Some have proposed that any new federal law to cut power plant pollution limit the requirements for western plants to the level and schedule recommended by the WRAP. As we understand it, the timetable for cutting SO2 under the WRAP recommendations is much slower than under S.556 (compliance by 2018 instead of 2007). The emissions remaining at western plants may also be higher than under S.556.
Given the special resource that western air quality represents, it is important to assure that an SO2 trading program does not result in a level of actual emissions in the west greater than that recommended by the WRAP. A regional cap on western SO2 emissions as part of a national SO2 trading program is needed to assure that the full emission reductions recommended by the WRAP are in fact realized in the west.
It is not entirely clear but it appears that representatives of some western generators are arguing that they should be allocated a greater share of the national cap on emissions than a national uniform formula would provide. The WRAP process is one of many facts that contending interests will no doubt bring to bear to support particular advantageous allocation formulas during the legislative process. While it deserves consideration, we see no reason why it deserves a presumptive priority over other competing arguments for different allocation approaches.
Some have argued that the west does not have a significant NOx problem. We disagree with that claim. Of course, California’s NOx-driven smog problem is legendary and still with us. But turning to the ten states in the western power grid outside California, the problems posed by NOx are also significant. Consider the following information assembled by the Clean Air Task Force and Environmental Defense:
§ Nitrogen oxide emissions have been climbing in nearly every western state in the past 30 years.
In sum, NOx causes significant problems in the west; power plants are a significant source; and their contribution to western NOx problems will grow unless they are cleaned up.
Turning to mercury, some have claimed that western power plants need special treatment for that pollutant as well. Again, we do not agree. Power plants west of the Mississippi emit over 16 tons of mercury—33% of the national mercury total from power plants. Nine of the eleven states in the western power grid have issued fish consumption advisories for some waterbodies due to mercury contamination.
Western power companies argue that it is not possible to achieve high levels of mercury control from sub-bituminous coal and lignite. These claims are not well-supported. Sub-bituminous coals do contain a higher proportion of elemental mercury relative to oxidized mercury, when compared to bituminous coals. Nonetheless, according to data collected from power plants by EPA (ICR data), power plants burning sub-bituminous coals can capture 75 percent or more of the mercury in stack gas with conventional controls. Fabric filters in combination with other controls have the highest capture rate (> 70%). The capture efficiencies vary depending on a number of factors, including the boiler type, SO2 controls, NOx controls, and coal-type. For example, based on stack tests conducted in 1999, higher capture efficiencies range from:
¨ 75% (Public Service Co. of Colorado, burning sub-bituminous coal in a tangential-fired boiler with a low NOx burner and fabric filter (FF))
¨ 79% (TX-NM Power Company, burning lignite in a FBC boiler with limestone injection and a FF)
¨ 84% (Intermountain Power Agency, UT, burning sub-bituminous & bituminous in a wall-fired boiler with a low NOx burner, FGD, and FF)
EPA data also demonstrate that the fraction of mercury that is elemental or oxidized varies widely from plant to plant, and even between units at the same plant. No generalizations about western plants as a category are appropriate.
Emerging technologies will improve mercury capture from western coals. Sorbent technology, including carbon injection, is capable of capturing a high percentage of mercury in stack gas. In the 2007-2008 timeframe, EPA estimates that activated carbon technology will be capable of capturing up to 85% of total mercury from sub-bituminous coals (presentation by Jim Kilgroe to MACT Working Group, August 1, 2001. Washington, DC). In addition, significant research is underway to develop more cost-effective sorbents and to optimize the oxidation of mercury upstream of the control device. DOE’s goal is to develop mercury technologies that will achieve 90% reduction by 2010. Finally, S.556’ integrated strategy of improved energy efficiency and increasing use of renewable energy will enable sharp cuts in mercury emissions throughout the United States.
A second claim made by western generators is that their mercury is innocuous because most of it is not deposited locally. This argument too lacks merit. Mercury deposition varies depending on a number of factors, including stack height, mercury species and precipitation. While EPA modeling does show that within a 30-mile radius of the plant, mercury deposition is less in an arid climate than in a humid climate, deposition is nonetheless still occurring. It would be wrong to assume that mercury from western power plants doesn't deposit locally or regionally. Elemental mercury can be oxidized (and deposited) anywhere from a few days to a few years, with deposition ranging from a few miles to a few thousand miles. Also, atmospheric chemistry and the chemistry of stack gas can change the form of mercury, causing reactions to change elemental to oxidized, and vice versa, thereby affecting deposition.
One deposition study underway by U.S. EPA and Tetra Tech is investigating the sources of mercury in two reservoirs in Colorado. Given that mercury fish consumption advisories have already been issued in many western states, it is apparent that mercury in the atmosphere is making its way into these aquatic environments.
In addition, to the extent mercury emissions from western power plants is not deposited locally, it is deposited further downwind, including eastern states. Allowing western plants to emit more mercury means more mercury gets dumped in states that lie to the east of these plants.
Western mercury emissions also add to the global pool of mercury. The primary way people are exposed to methylmercury is through the consumption of fish, and the majority of this exposure (for the general population) is from eating marine fish. Atmospheric deposition of mercury to the open ocean from the global pool of mercury is the cause of this contamination. Western power plants, like all other sources of elemental mercury, contribute to the mercury burden in the oceans, which comes back to us when we eat ocean fish.
The fundamental fact about mercury in coal is that for millions of years this source of mercury has been isolated from living things. By burning these mercury-containing fuels we are adding significant amounts of this poison to environments where humans and other species are exposed through a continuing accumulation in the food-chain. Once released from fossil fuels this mercury does not disappear; rather it builds up continuously. Prudent policy demands that we minimize the additional build-up of this toxin in the environment from all controllable sources.
Mr. Chairman and members of the Committee, this concludes my testimony. I am happy to answer any questions you may have.
Attachment: NRDC Report "Failure of Voluntary Commitment and Reporting to Reduce U.S. Electricity Industry CO2 Emissions
 US EPA, October 31, 2001, “Economic Analysis of a Multi-Emission Strategy,” at 24-28. (“EPA J-L Study”)
 ChevronTexaco and General Electric report that they can build a new IGCC generator with carbon capture for less than the cost of a new conventional pulverized coal plant and that the carbon capture equipment increases the project’s capital cost by about 4 percent with only a 2 percent efficiency penalty. O’Keefe, et al, 2001, “A Single IGCC Design for Variable CO2 Capture.” Presented at EPW Staff Briefing, October 17, 2001.
 Koomey, et al., October 18, 2001, “Assessment of EIA’s statements in their multi-pollutant analysis about the Clean Energy Futures Report’s scenario assumptions.”
 Kahn, “Bush is Revising Energy Policy to Address Global Warming,” New York Times, June 12, 2001, at 32.
 EPA J-L Study, Table 3. BAU gas use is 8.3 quads in 2010 and is 8.2 quads with CEF moderate measures and 7.7 quads with CEF advanced measures.
 The government-supported coal gasification plant in Beulah, North Dakota, is a notable exception. It is capturing CO2 and piping it to Canada to enhance oil recovery there.
 US EPA, 2001. Air Trends, Office of Air and Radiation. Ozone Air Quality at National Parks, http://www.epa.gov/oar/aqtrnd00/pdffiles/natpark.pdf
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