Overview

Carbon capture and sequestration (CCS) is a technology that stops large amounts of carbon dioxide from being released into the atmosphere by separating out this greenhouse gas from power plant emissions and injecting it into geological formations. The EPA is proposing the elimination of CCS requirements for new, modified and reconstructed fossil fuel-fired power plants. The new rule would worsen climate and other public health impacts.

Take Action

(1) Submit your Comment to EPA. By February 19th, click here to submit your comment at regulations.gov.

(2) Share your comment with your members of congress.

  • Senator Dianne Feinstein: (415) 393-0707, (310) 914-7300, (202) 224-3841, or email.
  • Senator Kamala Harris: (415) 355-9041, (213) 894-5000, (202) 224-3553, or email.

Find your Representative:

  • Rep. Mark DeSaulnier - 11th district: (510) 620-1000, (202) 225-2095, or email.
  • Rep. Nancy Pelosi - 12th district: (415) 556-4862, (202) 225-4965, or email.
  • Rep. Barbara Lee - 13th district: (510) 763-0370, (202) 225-2661, or email.
  • Rep. Jackie Speier - 14th district: (650) 342-0300, (202) 225-3531, or email.
  • Rep. Eric Swalwell - 15th district: 510-370-3322, 202-225-5065, or email.

Suggested Comment

Note: It is best to personalize or modify the wording. You do not need to be a scientist or expert to submit your comments. Add any personal experience you, your family or friends are having with the effects of climate change. You may also create your own comments using information from the references below.

Even if the elimination of carbon capture and sequestration (CCS) were to go into effect, EPA’s own calculations show that it would not make coal plants competitive enough to revive the industry. But if any energy companies did make the investment to build, modify or reconstruct, CO2 emissions would rise at a time when all reputable science bodies show that global warming is accelerating faster than previously thought and that urgent and dramatic reductions are needed ([2018 National Climate Assessment[(https://www.globalchange.gov/nca4), IPCC report: Global Warming of 1.5 Degrees Celsius). EPA is proposing legally questionable action that is at odds with science and will endanger its citizens.

Weakening CO2 emission standards in the U.S. has worldwide implications that come back to harm Americans. The administration continues to lobby for continued use of coal around the world, despite its impact on global warming. Weakening of U.S. CO2 standards, along with U.S. lobbying efforts, sends a dangerous message about relaxing emission standards to the many countries where coal-fired plants remain competitive. The IPCC’s 2014 synthesis report for its fifth climate change assessment report shows that CO2 reduction targets cannot be met worldwide without CCS. Increased emissions in other countries will worsen global warming, harm the U.S. economy and further endanger the safety of American citizens.

EPA is proposing emission standards that are weaker than emission levels already achieved by plants currently operating. As a result, the proposal would cause greater environmental harm. To justify weakening the standards, EPA raises questions about whether CCS is, in fact, an adequately demonstrated technology. However, this question was thoroughly analyzed when the requirement was originally established. And the examples EPA cites to question the viability of CCS are cases where the plants are operating and successfully capturing a significantly large portion of their CO2 emissions - much more than would be required if EPA’s proposal goes into effect.

To further justify the proposal, EPA has recalculated the costs of CCS. Yet the analysis does not consider a study released in November 2018 by the International CCS Knowledge Centre that finds significant cost reductions for future CCS. EPA does not present a rationale for why (the incorrectly calculated) increased costs for new coal plants are unreasonable. In its press release about the proposal, EPA states that it would “level the playing field so that new technology can be a part of America’s future.” The most urgent concern for America’s future is climate change. Leveling the playing field for fossil fuel or any other energy technology is a legally questionable criterion for taking action under the Clean Air Act.

EPA’s economic analysis acknowledges that no new coal plants are likely to be built in the U.S., whether or not the rule goes into effect. The analysis shows that there would be little or no emission changes or costs associated with the proposal. If this is the case, there is no rationale for weakening the rule and sufficient justification for maintaining it - which would ensure no greater harm to U.S. citizens.

Background

In 2015 EPA, under the Obama administration, issued strong CO2 emissions standards for new, modified and reconstructed fossil-fuel-fired electric power plants (steam generating units). The action was taken under the authority of the Clean Air Act. EPA determined then that partial carbon capture and sequestration (CCS) technology was technically feasible, widely available, and could be implemented at reasonable cost - factors that contributed to making it the “best system of emission reduction” required by the Clean Air Act. A few plants now employ this technology.

The current administration is proposing to reverse the finding that partial CCS is the best technology and relax CO2 standards enough so that they could be met without using CCS. The reversal is based largely on the claim that the technology is too expensive to industry. In the U.S., new coal-fired power plants are unlikely to be built, or reconstructed, whether or not they use this technology, because they are economically infeasible. However, in eliminating the requirement and claiming the cost is too high, the U.S. sends a dangerous message to other countries. The IPPC report – Global Warming of 1.5 Degrees Celsius – relies on CCS as an essential component for keeping global warming within 1.5 degrees Celsius. Most of the world can’t meet emissions targets without CCS, according to the IPCC’s 2014 synthesis report for its fifth climate change assessment. For countries that can do so, mitigation costs are much higher without CCS, according to the report says.

EPA’s proposal is another in a series of rollbacks that weaken environmental standards and climate protections, particularly with respect to the energy industry. The president and members of his administration are openly advocating for the continued use of fossil fuels, including coal, in the U.S. and around the world: the Energy Department secretary promoted the use of coal during the Poland Climate Summit last year, and the EPA acting administrator has stated that “…the use of coal worldwide has not peaked.” EPA’s proposal is specifically designed to benefit the coal industry.

References