It’s Only the Beginning

The EPA has proposed the following rules for CO2 emissions1:

  • For coal-fired power plants, including Integrated Gasification Combined Cycle (IGCC), 1,100 pounds CO2 per MWh.
  • For Large natural gas power plants, 1,000 pounds per MWh, and 1,100 pounds per MWh for smaller plants.
EPA Logo
EPA Logo

Why is the EPA issuing this proposed rule?

Make no mistake; the sole purpose of this rule is to cut GHG, specifically CO2 emissions, so as to stop global warming2.

The EPA’s documents show that the price of electricity from coal-fired plants, with full carbon capture, will be 2 to 3 times greater than the cost of electricity today.

This proposed EPA regulation is only a prelude to what must come next if the United States is to cut CO2 emissions 80% as stipulated by the EPA.

Cutting emissions from natural gas power plants substantially below 1,000 MWh must take place if emissions are to be reduced 80%.

In fact, CO2 emissions from existing natural gas power plants already exceed what would be allowed from all power plants if emissions are to be cut 80%.

Natural gas-fired power plants will be required to capture CO2, something that hasn’t yet been proven possible, but even if it is, it will increase the cost of electricity by 3 to 4 times its current cost4.

The EPA’s rule is predicated on its being possible to sequester CO2. They recognize this, and go to great lengths to prove sequestration is possible. They cite the National Energy Technology Laboratory (NETL) and the U.S. Geological Survey (USGS) as expert sources for this claim.

But, the claim is purely speculative and largely based on the use of CO2 for enhanced oil field recovery (EOR).

To put this in perspective, the volume of liquid CO2 that must be transported and stored from coal-fired power plants is approximately 30 million barrels per day, which far greater than the approximately 19 million barrels per day of oil consumed by the United States.

And this must continue every day of every year, for as long as we can see into the future.

Glaringly omitted is whether CO2 can leak back into the atmosphere after being sequestered, other than to say it needs to be studied5.

This is slim evidence on which to bet the future of the United States.

Tellingly, the EPA doesn’t include the cost of sequestration in its LCOEs. It’s akin to including the cost of the boiler, but not of the turbine.

When the cost of sequestration is added, the cost of electricity will increase by an alarmingly large amount.

The ability of the United States to cut CO2 emissions from power generation hinges on whether it’s possible to sequester CO2 underground, forever.

Without sequestration, carbon capture is nearly useless6.

But this is only part of the story. Even if CO2 emissions are cut 80% in the power generation sector, it will only reduce total U.S. emissions by less than 40%.

From where will the additional reductions come?

How will CO2 emissions from gasoline be cut 80%, since gasoline accounts for 20% of today’s total U.S. CO2 emissions? And what about CO2 emissions from industry, residential and other sources.?

The book Carbon Gauntlet describes this, and more, in great detail7.

None of this, of course, addresses China’s CO2 emissions that now exceed those of the United States. And, it doesn’t address India’s growing CO2 emissions.

Where is the EPA taking America?


  1. From EPA pg 15 -16, “This action proposes a standard of performance for utility boilers and IGCC units based on partial implementation of carbon capture and storage (CCS) as the BSER. The proposed emission limit for those sources is 1,100 lb CO2/MWh. This action also proposes standards of performance for natural gas-fired stationary combustion turbines based on modern, efficient natural gas combined cycle (NGCC) technology as the BSER. The proposed emission limits for those sources are 1,000 lb CO2/MWh for larger units and 1,100 lb CO2/MWh for smaller units.
  2. From EPA pg 17, “Greenhouse gas (GHG) pollution threatens the American public’s health and welfare by contributing to long-lasting changes in our climate that can have a range of negative effects on human health and the environment.
  3. CO2 emissions from natural gas power plants can only be done by removing them from the exhaust. The exhaust contains less CO2 than does the exhaust from a coal-fired power plant, making it much more difficult to capture the CO2.
  4. Referenced EPA Documents are available at  and
  5. From the EPA RIA chapter 4-15, “Potential sequestration sites must undergo appropriate site characterization to ensure that the site can safely and securely store CO2.”
  6. Small amounts, relative to the total amounts emitted, of CO2 can be used for EOR.
  7. See Amazon Kindle books at

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