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APPA: EPA rule on power plant emissions is poor public policy, relies on unproven technology


September 23, 2013

By Jeannine Anderson
Editor

APPA supports several aspects of President Obama’s proposal to address climate change, including his plan to increase energy efficiency efforts, streamline hydro power and other renewable resource development, and increase the use of nuclear power, the association said in a Sept. 20 statement on the Environmental Protection Agency's proposed rule setting strict carbon emissions for new power plants. "We also support the president’s call for an 'all of the above' strategy, including coal, when it comes to the fuels we use to produce electricity," APPA said.

"But the administration’s announcement today that the EPA’s New Source Performance Standard (NSPS) for new coal-fired power plants will require the implementation of carbon capture and storage (CCS) technology is unrealistic and does not in our view comport with the requirements of NSPS under the Clean Air Act," APPA said.

First, the administration "continues to base its belief in the viability of CCS by citing two demonstration projects, the Plant Ratcliffe in Kemper County, Miss., and the SaskPower plant in Canada," which are in the process of attempting to implement CCS, APPA said.  "Though both projects are admirable for attempting to advance the technology, neither of them has demonstrated that the technology is commercially viable," the association said.

Second, the administration "fails to mention that both the Kemper and SaskPower plants sit on or near oil fields, the only areas where CCS has been demonstrated to work. Locations such as these that are suitable for the injection of CO2 are very limited within the United States," the association said.

"Third, because CCS is an unproven technology, the financing for both the Ratcliffe and SaskPower plants required substantial government financial assistance.  For a project to become commercially viable, it must be financed on its own and, given the high risk of financing such unproven technology, it is extremely unclear where the funding would come from."

"Fourth, the EPA has failed to answer the very important questions of regulatory treatment and liability for CO2 once it has been captured by a plant.  Is CO2 an acid gas subject to Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) litigation?" Also, who will own and pay for the CO2 monitoring requirements 100 years after a power plant closes, APPA asked.

APPA said it considers the new EPA rule to be "poor public policy because it requires technology that is unproven and not commercially viable" and because it will have the effect of precluding options for new coal plants in the United States.

"Taking coal off the table as an option for new plant investments, as this rule will do, will also increase reliance on natural gas, which is already stressed as a fuel source," the association said. "APPA is very concerned that these developments will cause energy prices to increase considerably without new coal plants as a resource option."

The statement is posted in the Newsroom section of APPA's website

 

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