Copy of [Draft] 111d EJ Letter

[H simmens]

I am resending the sign on letter as a PDF for easier access.

Herb

[Michael MacCracken]

As an additional point in the letter in addition to the many reasons
they already list, it would seem that an analysis is needed of whether
investing the same amount of money might provide much more return and
benefits if invested in efficiency measures so there was into need for
the supposedly fuel that is created in this way (so do a real full cost
carbon and dollar accounting--including the cost of carbon, etc.). Given
many efficiency measures actually save money (and the amount grows over
time), it is a bit hard to see how CCUS is a good national
investment--better to put their funds into making buildings more
efficient, for example. Perhaps requiring such an analysis would make
clear to their investors that doing this does not make good sense.

Best, Mike

On 3/23/23 4:20 PM, H simmens wrote:
> I am resending the sign on letter as a PDF for easier access.
>
> Herb
>
>
>

> Herb Simmens
> Author A Climate Vocabulary of the Future
> @herbsimmens
>

[Jim Baird]

I agree with Mike this makes no sense.

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[Robert Chris]

Point of clarification for a nonUS person.

CCUS does not necessarily refer only to CO2 recovered for EOR. There are
many other industrial uses, particularly in the building sector.  Are
these not also under consideration in this set of proposed regulations?

The argument doesn't tip in favour of non-EOR CCUS, because almost all
CCUS is an abuse of resources.  But I'm just concerned that the focus on
EOR might be missing something.

Regards

Robert

[Seth Miller]

As a baseline, the numbers I’ve seen for electrifying boilers - a fairly standard electrification/efficiency investment - has a cost equivalent to about $50/ton CO2e. 

When carbon capture and storage costs below $50/ton, then there is a good case to be made for infrastructure investment. There is a subset of point source capture that meets this requirement. It’s not clear to me whether or not your average EOR meets this given the pipelines required between the point sources and oil wells. 

Making fuels out of the CO2 will cost substantially more than this.

Seth

-------

Seth Miller, Ph.D.

www.linkedin.com/in/sethmiller2

Check my blog at: perspicacity.xyz

[Chris Van Arsdale]

I'm going to be blunt, apologies.

I think this is a dumb letter.

The actual EPA request for comment is fairly reasonable, and basically boils down to: "What should we consider to call [alternative fuels, CCUS, efficiency improvements] clean? How should we measure it? What affordances should we allow?".

If CCUS doesn't work (or isn't clean), then it should be easy to measure that and have it not meet the proposed standard. Instead of trying to handwave a bunch of arguments why CCUS hasn't worked in the past and arguing an extreme position, why not just argue for a correct standard that covers those concerns?

- Chris

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[Dan Miller]

There is no fixed budget for saving civilization. Instead of asking whether money would be better spent on efficiency vs. CCUS, why not ask if money is better spent on making golf carts or Marvel movies vs. CCUS?

In order to preserve a livable climate for our children, we need to (1) decarbonize ASAP, including improving efficiency, electrifying everything we can, and using CCS for industrial processes while we figure out how to green them and replace them, (2) remove the 2.4 trillion tons of CO2 we have already emitted, and (3) temporarily use SRM while we do (1) and (2).

Looking at tradeoffs of efficiency vs. CCUS/CDR is missing the big picture. We are not on an acceptable path and we need to go all-in on action to address the problems we face. There is no shortage of money to address the problem. Spending less will cost far more. Perhaps cost everything.

Dan

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[Jim Baird]

Dollar for dollar

Thermodynamic Geoengineering is a global cooling method, deployed at scale,
that would generate 1.6 times the world's current primary energy, and remove
carbon dioxide (CO2) from the atmosphere. The cooling would mimic the
2008-2013 global warming hiatus. At scale 31,000 OTEC one gigawatt plants
are estimated to be able to: a) displace about 0.8 W/m2 of average global
surface heat from the surface of the ocean to deep water that could be
recycled in 226 year cycles, b) produce 31 terawatts (TW) (relative to 2019
global use of 19.2 TW and c) absorb about 4.3 Gt CO2 per year from the
atmosphere by cooling surface waters. The estimated cost of these plants is
roughly $2.9 trillion per year or 30 years to ramp up to 31,000 plants and
replace as needed thereafter, compared for example to the cost of world oil
consumption that in 2019 was $2.3 trillion for 11.6 TW. The cost of the
energy generated is estimated to be $0.011, or just over one cent/KWh.

https://groups.google.com/d/msgid/CarbonDioxideRemoval/016b01d95dc9%244fc154
20%24ef43fc60%24%40gwmitigation.com.

[Hawkins, David]

Let me add some context.  The question implicated by this letter is not what is the optimal strategy for cutting GHGs from the power sector. It is a narrower question: if EPA sets emission standards under the US Clean Air Act for fossil-fueled power generating units what must the Agency show to support a standard that achieves large reductions?

In June, 2022 the Supreme Court ruled that a standard must be based on the reductions achievable by techniques that are feasible to apply to the power plants themselves; EPA is not authorized to set standards that are based on shifting fossil generation to renewables or other non-fossil generation. Many of us disagree strongly with the Supreme Court's reading of the law but the Court has the last word.

Thus, if EPA is to set a standard that achieves large reductions, one of the most likely candidates is CCS, which is capable of reducing CO2 rates by 90% or more.

While the law requires EPA to justify a numerical emission limit based on the capability of an underlying technology like CCS, the power plant owner's obligation is just to meet the emission limit using any technique that actually meets the limit. It is likely that some plants will retire rather than install CCS and with the generous subsidies in the Inflation Reduction Act, that generation is likely to be replaced by renewables. So a numerical limit that is based on what CCS can achieve does not mean that all existing fossil plants will install CCS.

As far as the merits and demerits of CCS are concerned, the letter is wrong in claiming that CCS "doesn"t work" or that applying CCS will increase other emissions.

On EPA's web site anyone can peruse 3 years of hourly emission data from the Petra Nova CCS project that operated at the Parrish coal plant on Texas between 2017-2020.  That CCS installation captured CO2 from about 1/3 of the exhaust gas of one of the Parrish plant's generating units.  The data show high availability of the CCS unit in the last year of the project as the bugs were addressed and shows the CCS unit could capture 90% of the CO2 in the gas stream that it treated.

One can justifiably complain that emissions could have been reduced more if all of the gas stream had been treated but that does not support a claim that CCS "doesn't work."  It works as much as the rules require it to work. The problem is with the rules (or lack thereof, not with the technology."

As for the impact of CCS on other pollutants, it is well known in the technical community that Sulfur dioxide must be reduced to near zero levels to protect the CCS solvents.  The emissions data from the Petra Nova project demonstrate this; comparing days when the CCS unit was operating to days when it was off shows a huge reduction in sulfur dioxide emissions.  This is a key benefit because the fine particles from SO2 emissions are deadly.

It does take additional energy to run the CCS unit but it is technically straightforward to prevent any increase in other pollutants by upgrading PM and NOx control equipment.  Most CCS projects are expected to do this to avoid a more stringent New Source Review permitting process.

Will CCS prolong use of coal-fired power plants? Not if EPA sets a stringent emission standard. Such a standard will increase the costs of running such plants and that will mean they dispatch less and some will retire. The system result will be significantly less coal generation.

Safe pipelines are essential and the Sartaria rupture and release is inexcusable.  But the operating history of the CO2 pipeline network that has existed for decades demonstrates that is perfectly feasible to operate CO2 pipelines safely.  Clearly, inspections, enforcement, and pipeline siting rules all must be upgraded. Again, the issue is with the rules and their enforcement, not with the technology.

Bottom line is that under the Supreme Court's ruling, if we want to see a Clean Air Act rule that cuts emissions significantly from fossil plants, the EPA is likely going to base its rule on what CCS can do (possibly on what hydrogen firing can do as well).  This will result in less fossil generation, more renewables generation, and greatly reduced CO2 emissions.  The CCS retrofits that occur can be run effectively and safely; we just need to keep the pressure on the rule writers to adopt and enforce the necessary safeguards.

David Hawkins

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From: carbondiox...@googlegroups.com <carbondiox...@googlegroups.com> on behalf of Michael MacCracken <mmac...@comcast.net>
Sent: Thursday, March 23, 2023 4:48:15 PM

To: H simmens <hsim...@gmail.com>; Carbon Dioxide Removal <CarbonDiox...@googlegroups.com>
Subject: Re: [CDR] Copy of [Draft] 111d EJ Letter

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[Ron Baiman]

Agree with Robert C. Most of CCUS is fossil fuel industry crap that should rightly be vociferously opposed, but some is not.

My concern is that this is too broad brush (good versus evil framing) without getting at the real problem that in the cases described in the letter it makes no sense (per Mike's coment. This point could be made while appealing to the industry to be "a part of the solution" rather than "the problem", and redeploy their considerable resources and skills to for example "negative emissions technologies" that utilize existing fossil fuel natural gas fired power plant infrastructure to draw down more carbon than is emitted (See GT Peter Eisenberger HPAC presentation and Rev 2 podcasts).  Though not a long term solution, in the short run this kind of transition technology is better than zero emissions energy production. There are of course many roles in any political campaign,  and militants (that I've been most of my life) play an important role in pushing the envelope, while others try to make "insider" progress within the existing balance of forces. But perhaps as "the expert community" such as we are, our best role in this case would be to point out these nuances? See "framing discussion" at the beginning of paper attached below.

Best,

Ron

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