Base-e Blog Practical Strategies for Emerging Energy Technologies en-us The EIA Has Resorted to CO2 Intensity in their 2017 WW Forecast The EIA just released the International Energy Outlook for 2017 and declared that Carbon Intensity is projected to continue to fall in the Reference Case.

I looked for a definition of and the assumptions contained within the Reference Case, specifically as it relates to the much talked about Clean Power Plan (CPP). There is no mention of, or reference to the CPP in this 2017 International Outlook. Here is what it says.

But, the full implementation of the CPP appears to be built into the forecast and the associated claim of reduced energy intensity.How do I know?

Here is the Reference Case forecast:

The new International Outlook has the U.S. at 5072.6 Mmt in 2050

The EIA 2017 U.S. Energy Outlook for U.S., published in January of this year, shows the Reference Case CO2 emissions in 2050 at 5084.2 Mmt and explicitly included the full implementation of the CPP.

I provided the data for that January Outlook earlier this year on the TMI blog, and on my own website ( Here it is, again:

The Reference Case U.S. forecast, for all intents and purposes, is the same level.

Therefore, the new International forecast suggests that the CPP will be fully implemented in the U.S., but our current political rhetoric does not. I guess the EIA has created some of that “plausible deniability” by referring to “current policies” and “existing government regulations”. The rest of their Reference Case narrative is mumbo jumbo.

I keep referring to this MIT technology Review article and graphic by Mike Orcott, originally published in their 2012 Technical Review. It is still the best graphic that I have seen to dimension the problem.

You can see that the U.S.A portion of the 6℃ scenario is 5.4 Gt (5,400 Mmt). The CPP impact in the U.S. forecast is 481.2 Mmt in 2050. If this value is added to the current EIA forecast, the adjusted U.S. value becomes 5,565.4 Mmt.

This Carbon Intensity language tries to put a happy face on our efforts. As I have stated before, this CO2 Intensity is, more or less, the same metric as CO2 per GDP that both China and India advocate. They are still growing their economies.

If you look below at the U.S.A again in the Orcott graphic, the current 2050 Reference Case forecast level is still 4x the 1,300 Mmt level required to reach 2℃

The worldwide totals shown in the EIA 2017 International Outlook are plotted on the Orcott graph and, if met, suggests a 4.5℃ level.

I have no reason to believe that the rest of the world will be any more successful than the U.S., since they too are in a growth mode and that this also suggests that the 4.5℃ is optimistic.

Wed, 27 Sep 2017 07:51:27 -0600
The 2017 EIA Annual Energy Outlook - "5°C or 6°C?";5°c-or-6°c?quot; The 2017 Annual Energy Outlook, released in early January, provides a CO2 emissions forecast, which includes a base Reference Case along with side cases that examine the forecast sensitivity to six basic assumptions.

The Reference Case assumes that the U.S. implements the Clean Power Plan (CPP).

The six side case variations are:

  • High & Low Economic Growth
  • High & Low Oil Price
  • High & Low Oil & Gas Resource & Technology

In addition, the EIA has also provided a forecast for the Reference Case that assumes the U.S. does NOT implement the Clean Power Plan.

The report generator provides both a U.S. Electric Power and a U.S. Energy-Related Forecast. The report generator is available through a link on its website ( report generator does not allow the user to combine the effects of these side cases.

There are eight cases in all. I have found it useful to arrange these case results from the U.S. Energy Related Total, high to low, to get a sense of their relative impact.

Note, that there is hardly any difference in Electric Power CO2 emissions except in the Reference Case without CPP. All the other cases are in the 1550 Mmt range and there is hardly any impact beyond 2030. This is largely the result of the underlying generation mix assumptions of 70% NGCC without CCS, in combination with 30% renewables, and that the conversion from coal to NGCC is virtually complete by 2030.

The impact of the CPP is shown below, and is in keeping with the approximately 400 Mmt (0.4 Gt) in the AEO2016 edition forecast for 2040.

Given the new direction articulated by the incoming Trump administration, a new “worst case” needs to be defined. The prevailing rhetoric would suggest a scenario as follows:

  • No CPP ( x1.305 & 1.095)
  • High Economic Growth (x1.009 & 1.078)
  • Low Oil Price (x1.004 & 1.058)
  • High Oil & Gas Resource & Technology (x1.003 & 1.026)

The values shown are the Electric Power and Energy Related values, respectively, compared to the reference case with CPP.

The combined effects of these in 2050 are x1.327 & x1.282 respectively, again, compared to the Reference Case (with CPP). If these factors are applied in combination, the resulting 2050 U.S. Electric Power Emissions are 2052.4 Mmt, and the Energy-Related Emissions are 6516.3 Mmt (6.5 Gt), effectively the same emissions we have today.

The Worldwide CO2 emissions, based on the AEO2016 are shown in the following table, along with a calculated U.S. percent contribution.I have extrapolated the 2050 U.S. Energy-Related Emissions without CPP to the estimated 11.4% of the total. Should that remain the case, this set of combined assumptions results in a Worldwide Emission total of 57.0 Gt.

The 57.0 Gt puts the world on a 6°C trajectory. I’ll leave you locate this on the Carbon Capture Conundrum plot. Hint…it is 3x the 2°C target and 4x the 1.5°C target.

The U.S. portion of the 6°C, 58 Gt Worldwide emissions in 2050 is 5.4 Gt, vs. the projected 6.5 Gt with combined effects as noted above.

If the same logic were applied to the Reference Case (with CPP), the 5084.2 U.S. Energy-Related CO2 emissions would become 48.8 Gt Worldwide, at approximately 5°C.

The AEO2017 also offers a metric of mt per Capita, presumably to support the claim that emissions are declining. We have seen this logic attempted before, either as CO2 tonnes/GDP or some other production index. CO2 per Capita is just another surrogate for these output-based measures that allow emissions to grow along with economic output.

The good news is that this output-based logic is similar to those proposed by China and India. The bad news is that we are nowhere close to the level required to reach the 2°C/450ppm goal.

Sun, 22 Jan 2017 11:00:40 -0700;5°c-or-6°c?quot;
Finding the Middle Ground Between Coal and Climate Change

Huntley coal-fired power plant in Tonawanda, New York

At some point, the country will need to find the middle ground between "The War on Coal" and the imperatives of "Climate Change". I have spent the last 12 years on the inside of this Power Plant/Climate Change debate. Here is my take:

Coal is not competitive because of the EPA New Source Performance Standards (NSPS), first issued in 2014. The NSPS mandated that coal-fired power plants deploy Carbon Capture (CCS), but allowed natural gas power plants to be permitted without doing anything. This was not done explicitly, but by setting the new power plant emissions limits at a level that the natural gas plant could meet “unabated”. This was a “Business as Usual” for the natural gas team.

Under this scenario, the coal plant was 5x the first cost and half the efficiency. This is the War on Coal. The EPA is aware of all this, their efforts were intentional and were supported by The Sierra Club, itself funded by the gas industry. It suited the EPA’s own hidden agenda as well. The EPA did not want to capture CO2 because it has no plan to deal with CO2, if it were to be captured.

On top of that, the gas price dropped precipitously. Some like to deflect their regulatory role and simply blame the gas price for the coal industry demise. It was the regulation first, then compounded by the fall in natural gas cost.

The "coal guys" first tried to make it all go away, but without success. They then lobbied for their own standard and EPA was happy to oblige in 2015 with a NSPS modification in 2015. The change did not materially affect the competitive positioning of the two offerings. Coal was still over 3x the first cost and had a 30% efficiency penalty.

Neither of these EPA standards mentions Climate Change or climate targets.

The Energy Information Agency baseline scenario models the build out an entire fleet of natural gas units without abatement and implementation of the Clean Power Plan. That scenario forecasts the U.S. to emit 5044 Mmt/year of CO2 in 2040. The U.S. CO2 budget for a 2°C target is 1300Mmt in 2050. The current trajectory with full implementation of the CPP is more than 3x the target. At the same time, we will have reached the impact limit of fuel switching from coal to gas.

Virtually all of the IPCC scenarios that suggest a 2°C/450ppm could be achieved include both Carbon Capture (CCS) and Nuclear. CCS is currently on “life support” and most of the nuclear projects have been shelved. They too cannot compete with the unfair competitive advantage of unabated natural gas. This is also the reason nuclear plants are being shut down, rather than being upgraded and relicensed to extend their life.

CCS is the key to giving both the Coal Industry a fair shot, and the world in meeting any reasonable climate goals, but only if applied equally and to all types of power plants. You cannot force coal to capture, while giving gas a free pass. CO2 is CO2. There is no such thing as clean CO2.

It is essential to require both coal and natural gas power plants deploy CCS to reach 250-300 lb-CO2/MWh. If done, we could be on 2°C/450ppm trajectory and the CCS learning curve.We would use the lower natural gas price to offset added cost of CCS, so as not to penalize end users.

Eliminating CO2 from the electric power generation is also the critical enabler to realizing the impact of electric vehicles.

We all agree that a value must be put on CO2, so that it can affect investment choices.

Cap and Trade is one method, but it has two components. The trade is easy. The cap is political, given to influence peddling, etc. Politicians have already proven that they cannot effectively handle that responsibility with anything like a timely and fair implementation.

“Revenue Neutral” tax and rebate/dividend schemes have been proposed. The tax is ok, but why give the money back? Use the money to solve the problem!


My favorite is to implement a “CO2 (waste) Disposal Fee” based on a calculable cost to dispose of it. I would use those funds to build pipelines to pre-permitted, remote underground locations for storage in perpetuity. The Federal Government would need to assume long-term liability.

Note….This entire effort would fit neatly into any infrastructure build-out and rural jobs program.

We also need to buy land and plant trees, as well as invest in mass transit.

Wed, 30 Nov 2016 14:29:41 -0700
Earth to China

I need you!

My, thought to be, principal advocate and benefactor has just shot itself in the foot and I am likely to become collateral damage, big time!

I need you to step forward and take the lead on today's important Climate Change imperatives, now cast aside by the (not so) United States of America.

You and you alone can help me.

You certainly have the money and the need, and you do seem to understand the problem. You also know how to get things done and are largely unencumbered by the interveners.

Please set the example, take the lead and turn this problem into a giant export opportunity.

Your friend,


Mon, 21 Nov 2016 11:17:00 -0700
Disingenuous - (and, not the least bit surprising) SNL published an article entitled “As gas tops coal for carbon emissions, Sierra Club sees next climate fight”, based on an interview with Lena Moffitt. The article was written by Annalee Grant on August 18, 2016 and can be found on the internet (

The article included some of the familiar EIA data and charts as follows:

According to SNL, the Sierra Club just acknowledged that…

"As we're trying to meet our climate goals, it is very clear that we cannot afford to expand infrastructure and reliance on fossil fuels, including gas."

Other reported comments and observations included:

"In 2015, natural gas consumption was 81% higher than coal consumption, and their emissions were nearly equal. Both fuels were associated with about 1.5 billion metric tons of energy-related CO2 emissions in the United States in 2015," the EIA report said.

"In addition to this being a significant wake-up call for hopefully all Americans, it's also a real indication of where the next climate fight is going to be and that really is with gas"

"As we're trying to meet our climate goals, it is very clear that we cannot afford to expand infrastructure and reliance on fossil fuels, including gas."

"It's incredibly encouraging that our country has been able to move away from coal in the way that it has, and that's a trend that we want to see of course for the climate benefits and the public health benefits"

"At the same time, we do need to ensure that that energy is not backfilled with gas."

"Unfortunately, the theory that gas can provide an energy bridge has stuck around too long, and is frankly just not true."

"If you take the full life cycle view, gas could be just as bad for the climate as coal."

The extraction of natural gas is also responsible for methane emissions, which the EPA has said has a climate change impact 25 times greater than carbon over a 100-year period.

Further EIA research anticipates a 55% increase in gas extraction and a 24% hike in gas consumption by 2040, according to Moffitt, who expressed concern that the expansion could push the U.S. well over the greenhouse gas reductions pledged in Paris in December.

"Just that consumption alone, if you consider the methane emissions, will cause us to blow past our international climate goals, which is unacceptable if we want to keep this planet in a livable state."

She worries that reducing coal in favor of gas could mean trading one greenhouse gas for another.

Looking more closely at coal- and natural gas-fired power generation, coal remains the top emitter of carbon, although those emissions are trending downward as coal capacity shrinks.

Carbon emissions from natural gas generation have risen moderately, as more gas capacity has been added, but coal in 2015 still exceeded natural gas by 904 million tons of emitted carbon, according to SNL Energy data.

The Sierra Club will respond by doubling down on efforts to both fight investments in gas and prioritize renewables and energy efficiency.

SNL observed that, “News of rising carbon emissions from gas consumption was greeted with dismay by the Sierra Club, which has maintained a major campaign against coal-fired generation. The group has also lobbied against the expansion of natural gas infrastructure, and Beyond Dirty Fuels Campaign Director Lena Moffitt said the EIA data underscores the importance of that fight.”

This is the data behind the first EIA chart. To be clear, the ~100 Quad includes all energy-related use.

A more detailed and fascinating breakdown of that ~100 Quad U.S. Energy Consumption is available from the Lawrence Livermore National Laboratory (LLNL).

The energy-related terminology in these data encompasses the natural gas consumption at 27.27 Quads from the data table, or 28.3 Quads from the LLNL chart, with the pathways as shown.

Natural gas consumption for Power Generation was 9.99 Quads in 2015.

The efficiency of the primary energy conversions, shown as percentages in red (black for Electricity Generation) are:

  • Electricity generation (all fuels)  - 33.0%
  • Residential - 64.9%
  • Commercial - 65.0%
  • Industrial - 80.0%
  • Transportation - 21.0%

The two areas with the greatest opportunity improvement in overall efficiency of energy use are the power sector and transportation sectors. Both of these will increase the role of and pressure on CO2 emitted for electricity production.

It is completely disingenuous, but at the same time, not the least bit surprising for the Sierra Club to cite the new EPA Methane Rule, yet remain completely silent on the emissions from natural gas fired power plants.

The CO2 emissions for power generation were 1891.3 Million metric tonnes (1.891 Gt) in 2015. Natural gas power generation accounted for 524 Mmt (0.524 Gt), or 27.7% of the total.

The May 12, 2016 EPA Final Ruling to Reduce Emission from the Oil & Gas Industry, which they do allude to, has a stated goal of reducing emission by 40-45% from 2012 levels, by 2025. The rule is intended to capture 510,000 short tons of methane, with the equivalent of 11 Million metric tonnes of CO2 (0.011Gt).

Carbon Capture is not now, nor has it ever been in the EIA or the Sierra Club narrative. Successful deployment of Carbon Capture and Storage (CCS) would serve to enable coal. Such an outcome would be intolerable for Sierra Club, which is why they ignore its potential deployment. CCS is the real “Bridge”, not natural gas as has been claimed.

The EIA Reference Case forecasts data is shown below indicating 653 Million metric tonnes (.653 Gt), of CO2 from natural gas fired power plants in 2040, dwarfing the impact of methane leakage.

The forecast includes a 45% increase in power from natural gas, but only indicates only 24% increase in CO2 emissions, with natural gas accounting for 35.9% of the supply.

The 2015 and 2040 specific output values expressed in lb-CO2/MWh are easily calculated:

Natural Gas 2015: 524.5 Mmt x 2205 lbs/tonne/1113.7 BkWh = 1038 lb-CO2/MWh

Natural Gas 2040: 653.0 Mmt x 2205 lbs/tonne/1617.9 BkWh = 890 lb-CO2/MWh

Coal 2015: 1340.2 Mmt x 2205 lbs/tonne/ 1319.9 BkWh = 2239 lb-CO2/MWh

Coal 2040: 885.0 Mmt x 2205 lbs/tonne/ 884.3 BkWh = 2207 lb-CO2/MWh

These 2040 values are consistent with unabated coal-fired power plants at 2200 lb-CO2/MWh and indicate only a 1.5% improvement in the 2015 rate.

The natural gas combined and simple cycle units, also unabated at 890 lb-CO2/MWh, do include a 15% reduction in CO2 per MWh, presumably the result of a shift in the mix toward the more efficient combined cycle configurations. The 890 lb-CO2/MWh for natural gas in 2040 would represent a mix of approximately 70% combined cycle and 30% simple cycle units.

If CCS were to be applied at 90% capture, the 1551 Mmt is value would become 155 Mmt and the resulting U.S. total would become 4900 Mmt (4.9 Gt).

It should be noted that the 1551 Mmt CO2 emission for electric power is 3-8 times the 200-500 level required to reach the 2°C 450 ppmv goal. We will need CCS on both coal and gas to reach this level.

The U.S. “target”, if there is such a thing, is 1.3 Gt. These data suggest that we are closer to a 4 or 5°C trajectory.

I have said this before, but it is worth repeating:

If we all had the same “objective”, we would use the current lower cost of natural gas to offset the added cost of CCS, put CCS on Natural Gas Combined Cycle power plants and in so doing, actually be on the CCS learning curve and the 2C°/450ppm trajectory.

Sat, 10 Sep 2016 03:31:26 -0600
The EIA just said that Clean Power Plan is not good enough!

      Of course, they did not say it that way, exactly, but here is what they did say.

      The Center for Strategic and International Studies published its International Energy Outlook 2016 on May 11, 2016. I commented that this report which, unlike others, included projections to 2040 and the impact of the new EPA Clean Power Plan.

      The summary’s conclusions state that 75% of energy use in 2040 will come from fossil fuel and that the forecast for worldwide power generation CO2 emissions was 43.4Gt, up from 33.5Gt in 2015, a compound growth rate of +1% per year. I commented on this forecast in my previous blog. (

      This May 11 report was quickly appended with the May 17 Annual Energy Outlook 2016 Early Release of an Annotated Summary of Two Cases (

      The two early release cases and stated conclusions are:

      Implementation of the Clean Power Plan (CPP) using a mass-based approach reduces annual electricity-related carbon dioxide (CO2) emissions to between 1,550 and 1,560 million metric tons (MMT) in the 2030-40 period, substantially below their 2005 and 2015 levels of 2,416MMt and 1,891MMt, respectively. Coal’s share of total electricity generation, which was 50% in 2005 and 33% in 2015, falls to 21% in 2030 and to 18% in 2040.

      Even without the CPP, electricity-related CO2 emissions remain well below their 2005 level at 1,942 MMT in 2030 and 1,959 MMT in 2040; this outcome reflects both low load growth and generation mix changes driven by the extension of key renewable tax credits, reduced solar photovoltaic (PV) capital costs, and low natural gas prices.

      Several observations on these projections:

      • They just admitted that a full implementation of the CPP will not allow us to reach a 2C/450ppm target.
      • The coal to gas conversion is 82% completed by 2040.
      • There is only 400 MMt (0.400Gt) difference between the full implementation of the CPP and No-CPP case.
      • The total U.S. CO2 emissions in 2015 were 5721 MMt, split 1925/3346 MMt PowerGen and Non-PowerGen, respectively.
      • The forecast asks that you believe that natural gas prices will trend even lower than they are today, through 2040.
      • It also asks that you ignore system integration costs, not yet fully considered in the renewables claims about cost competitiveness.
      • In addition, it asks that various tax credits be extended throughout the forecast period while both Germany and Denmark are just now putting caps on renewables penetration.

Here are the two cases and the assumptions they are based on.

        The actual numbers provided suggest to that this improvement in use efficiency is more like 2.12% per year. In other words, efficiency of use will offset any Real GDP increases.

        There is no real discussion of the Non-PowerGen values, except a decline of 0.3% in Energy per Capita Use. I have assumed this is a similar offset against the 2.23% per year Real GDP growth, which presumably affects the Non-PowerGen values.

        This is my attempt at reconciling the comments and values provided.

        The stated endpoint in 2040 of 1560 MMt is 3x the 500 MMt level required and 8X the 200 MMt

        We have not explicitly addressed Non-PowerGen actions. Lacking anything specific, the best-case combination is 1560/5812 MMt, resulting in 7372 MMt in 2040.

        With these assumptions, the world total is 47Gt/year in 2040.

        What is new is that the EIA, presumably with EPA’s blessing, is now trying to shift the conversation from absolute CO2 reductions expressed in tonnes of CO2, to tonnes per unit of GDP.


        “Tonnes per GDP” is, by definition, “Business as Usual” and an admission that the CPP will not get us to 2C/450ppm.

        Here is that redirect language along with some economic “mumbo jumbo” that says Real GDP will increase at 2.23% per year and that there will be an improvement of 1.8% per year in energy use per GDP.

        The OECD provides a GDP Forecast in its long term Economic Outlook 2009-2060. I have added the comparable values back to 2005 from World Bank Data to bridge the data from the historical to the forecast.

        Here is that data:

        • The key factor is the calculated MMt of CO2 per million dollars of GDP, 0.000492 in 2015.
        • There was a 10% reduction in this value for both the 2005-2010 and the 2010-2015 periods, based on the data and can be interpreted broadly as an improvement in overall efficiency of use.
        • The 1900GtCO2 in the 2C/450 ppm already consumed between 1870-2011, is included as the 2012 starting value in the cumulative calculation.

        The OECD GDP forecast is shown below along with the important scaling metrics.

        • The OECD GDP Forecast is shown without modification.
        • I assumed that same efficiency of use improvements, x0.90 for each 5-year increment, throughout the forecast period to 2060.
        • I added the scaled yearly increment based on this GDP Forecast data and underlying efficiency of use assumptions.
        • This efficiency of use assumptions are not likely to apply uniformly around the world, but that assumption is embedded in the calculation, nonetheless.
        • We bust the 2900Gt budget in 2041 and reach 3719Gt by 2060.
        • This is equivalent to 550-600 ppm and perhaps 4°C temperature rise.
        • If the 0.90 becomes 0.95, we bust the budget in 2038 and reach 4272Gt in 2060.
        • Annual release in 2040 becomes 55Gt and 69Gt in 2060.

        If the U.S., China and India all argue for CO2 tonnes/GDP, it makes sense, that this will become the world’s standard measure

        We have no chance at 2C/450ppm and it is important that we stop pretending that we are doing enough.

        We must also stop destroying the opportunity for Nuclear and CCS technologies with the underlying subsidies for natural gas power generation. We will need both of the targets to meet any kind of meaningful climate change targets.

        I have said this before, but it is worth repeating.

        If we all had the same “objective”, we would use the current lower cost of natural gas to offset the added cost of CCS, put CCS on Natural Gas Combined Cycle power plants, and in so doing, actually be on both the CCS learning curve and the 2C°/450ppm trajectory.

Sun, 03 Jul 2016 14:48:25 -0600
EIA 2040 Forecast The Center for Strategic and International Studies published its International Energy Outlook 2016 on May 11, 2016.

A reference to the follows the tag line “Independent Statistics & Analysis”. I’m all for that! What’s not to like?

What is fascinating about this report is that it actually makes a forecast out to 2040. Most forecasts done to date stop at 2030, a date corresponding to the new Clean Power Plan (CPP) and other advertised Climate Change initiatives.

The report breaks down energy use between OECD and Non-OECD countries 35%/65%, as can be seen in the chart, shown below. The comment identifies most of the increased energy use in the Non-OECD countries.

The report further breaks down the energy related CO2e intensity of energy use, expressed in kilograms CO2 per million Btu, again, between OECD and Non-OECD countries. Those values are 49 kg-CO2/mmBtu for the OECD and 55kg-CO2/mmBtu, respectively and as indicated on the chart below.

The weighted average intensity is 52.9 kg-CO2/mmBtu.

The interesting part of this report is that, unlike others, the forecast includes projections to 2040, with the impact of the new Clean Power Plan.

I have “eye-balled” these charts and have estimated this is 820 Quad, which at 52.9 kg-CO2/mmBtu is 43.4Gt of CO2 from the energy sector. The report says 43 and 815 Quads.

I plotted this forecast value on the previously published chart of scenarios from the Intergovernmental Panel on Climate Change (IPCC) AR5 review, shown below.

The summary conclusions in the report state that 75% of energy use in 2040 will come from fossil fuel.

The unavoidable conclusions are:

  • The world is not even close to where it needs to be on prevention
  • We are on an increasing trajectory and headed toward 4°C, if we are lucky
  • The CPP contribution is minimal and only affects Coal
  • Natural Gas generation is unaffected by CPP, since it has a waiver on its “½ of Coal” emissions
  • We are not yet being honest with ourselves
  • President Obama does not know this

The EIA presentation is available here:

Sun, 29 May 2016 06:56:54 -0600
“Mission Accomplished?”“mission-accomplished?” That would depend on how the “mission” is defined…right?

The Sierra Club published a Fact Sheet dated November 3, 2015, “Accelerating the U.S. Coal Phase Out: Leading by Example in Paris and Beyond”, in preparation for the COP21 conference.

Their Figure 1, shown below, offers a summary view of the progress to date for both the Electric Power Sector and the U.S. in total.

Their Figure 3, below, indicates the Electric Power Sector contribution along with several important future scenarios. The graph and the paper itself, provide important understandings, insights on the projections and their associated assumptions. I have added the vertical lines to pick off data for the various referenced dates.

The actual write-up offers further information on assumptions, as well as a few specific values for these scenarios. I have used those values, where available, to tabulate the data. The U.S. totals are also shown, if electric power generation is 38.5% of the total.

The scenarios and their end-point values are:

  • -Coal Replaced with Natural Gas at 1790Mt in 2025
  • -Projected Electric Power Sector Emissions under the Clean Power Plan at 1600Mt in 2030
  • -Coal replaced with Clean Energy at 1563Mt in 2025

The Sierra Club has defined its mission in their “Beyond Coal” initiative, but their actions and words suggest the mission to be “Killing Coal”. They make a point of their success in the document with their Figure 2, below.

But, shouldn’t the mission be “Killing the Emissions from Coal (& Gas)”? Or, even more appropriately, something like “Achieving 2°C/450ppm by 2050”? 

The 2°C/450ppm trajectory at 16Gt world total requires a total U.S. emissions level of 1.3Gt (1300Mt) in 2050. The Electric Power Sector portion of that at 38.5% is 500Mt, assuming balanced contribution. If a balanced contribution proves too difficult, as is likely, the Electric Power Sector may have to reach 200Mt.

Why is this so-called “...Leading by Example…” document silent on actions beyond 2030 and below 1500Mt?

If anything, I find the Sierra Club position to be “misleading” and very much in service of their mission of “killing coal”, but not our mission of dealing with Climate Change. The combination of fuel switching and a further shift to renewables, alone, will not put the world on a trajectory to reach 2°C/450ppm.

I have said this before, but it is worth repeating.

If we all had the same “objective”, we would use the current lower cost of natural gas to offset the added cost of CCS, put CCS on Natural Gas Combined Cycle power plants, and in so doing, actually be on the CCS learning curve and be on the 2C°/450ppm trajectory.

The current course of action will likely waste time that we simply do not have.

You can find their fact sheet here:

Mon, 16 May 2016 08:50:05 -0600“mission-accomplished?”
Competition Under the 2015 EPA Clean Power Plan Under the new Clean Power Plan, the EPA calculates state goals based on the Best System of Emission Reduction (BSER), and has now established separate emissions performance rates for coal and natural gas plants, as follows:

  • An interim emissions rate for existing coal units of 1,534 lbs CO2 per Net MWh, and a final rate of 1,305 lbs-CO2 per Net MWh
  • An interim emissions rate for existing natural gas units of 832 lbs CO2 per Net MWh and the final rate of 771 lbs-CO2 per Net MWh

The following table has been modified from the original 2014 version to calculate the Advanced-USCPC CO2 emissions based on a 50% LHV value with the 203.3 lb-CO2/mmBtu carbon factor. The NGCC values are shown, as before.

The Natural Gas Combined Cycle (NGCC) power plant meets the 832 lb-CO2/MWh interim level now, and the final 771 level without any form of CO2 abatement, if expected efficiency gains are realized.

The graphic shown below was developed as part of an International Energy Agency “Road Mapping” exercise toward a High-Efficiency, Low-Emissions (HELE) coal fired power plant, shown as an Advanced Ultra-Supercritical Pulverized Coal (Advanced-USCPC).

The graphic indicates that at 50% LHV efficiency, the CO2 emissions would be ~1477 lb-CO2/MWh (~670 gCO2/kWh).

The Advanced Ultra Supercritical Pulverized Coal Plant(USCPC) at 1540 lb-CO2/MWh, would appear to meet the interim full load threshold level of 1534 lb-CO2/MWh, but another 15% efficiency improvement would be required to meet the final threshold of 1305 lb-CO2/MWh. Either that, or 15% Carbon Capture would be required.

In the most optimistic scenario, these new thresholds would position a NGCC without abatement against the Advanced-USCPC, also without abatement.

There are no first cost estimates for the Advanced-USCPC, but its lower efficiency predecessor was at least 3x the first cost. The efficiency, defined above, favors the NGCC. It should be noted that this comparison assumes significant efficiency improvement in both the NGCC and the Advanced-USCPC. Industry experience to date suggests that gas turbine concepts are much more likely to realize these efficiency improvements than coal-based efforts, and to reach them sooner.

The fuel cost differences are also narrowing, as shown in the following data extracted from the Energy Information Agency’s August 2015 year-over-year comparison, reducing coal’s historical price per mmBtu advantage.

At a nominal 550MW, the annual fuel cost difference is $23 million per year, in favor of the Advanced-USC, requiring a 40-year simple payback on the ̴$1.0 billion first cost difference.

If the differences in CO2 emissions were added at $60/Mt, the combined fuel and CO2 operating costs would shift in favor of the NGCC at $30 million per year.

The breakeven point would be about $25/Mt of CO2 at the fuel and efficiency rates.

A couple of things are happening here:

  • This dual standard concession is the result of the successful coal industry challenge on whether CCS was a “commercially available” technology. The EPA is prohibited from mandating a technology that is not “commercially available”.
  • The EPA is pandering to the coal industry by giving them their own standard and more importantly, the opening to dismiss CCS as a laboratory-level R&D level technology in hopes of building coal plants without CO2 abatement.
  • Natural Gas Combined Cycle Power Plants will continue to be built without doing anything about CO2 emissions. This has been the EPA’s primary objective throughout and that objective remains intact. This is Business as Usual dressed up to look like climate action.
  • In so doing, this EPA has, once again, chosen not to support CCS technology development, acknowledged to be part of any 2°C/450 ppm target.
  • CCS has been “kicked down the road” until 2030, at a minimum, when we “finally” realize that deploying CCS on NGCC plants is required to reach at 2°C/450 ppm level. We know that now! We are just wasting 15-years that we will wish we had. Mother Nature does not allow “do-overs”.
  • This is a recognition that we are on 4°C/720-1000 ppm trajectory, and that seems to be OK!
  • ……Really?

OBTW….It should be noted that CO2 that comes from a coal plant is the same as the CO2 that comes from a gas plant. The original standard was correct in that the threshold(s) was independent of source.

In the end, it is just CO2!

Competition under the EPA Clean Power Plan.pdf

Sat, 21 Nov 2015 08:17:26 -0700
Renewable Energy System Integration Costs The “Tragedy of the Commons” is an economic theory first authored by Garrett Hardin. It states that individuals acting independently and rationally according to their own self-interest, behave contrary to the best interests of the group as a whole, by depleting some common resource.

We normally think of the “Commons” in conjunction with Climate Change in general or depletion of the ocean’s fish stocks, but the “Commons" in the case of Variable Resource Energy (VRE), such as wind and solar, is the grid that provides essential integration support necessary to their success.

John Thompson, at the time, Director of the Fossil Energy Transition Project for Clean Air Task Force, made a presentation at the Pittsburgh Carbon Capture & Sequestration Conference in April 2014. The topic was System Integration as related to renewables.

The original work was authored and presented Ueckerdt, Falko and Hirth, Lion and Luderer, Gunnar and Edenhofer, Ottmar, System LCOE: What are the Costs of Variable Renewables? (January 14, 2013). Available at SSRN: or

The following graphic from that paper illustrates the key take-away and integration cost components.

Highlights as published in the paper:

  • A proposed new metric, System LCOE, that includes both generation and integration costs be used to determine the economic comparative costs of wind and solar power
  • Integration costs of wind power can be in the same range as generation costs at moderate shares (~20%).
  • Integration costs can become an economic barrier to deploying Variable Renewable Resources (VRE) at high shares.
  • A significant driver of integration costs is the reduced utilization of capital-intensive,conventional plants.
  • An economic evaluation of wind and solar power must not neglect integration costs.

At the moment, integration costs are an afterthought and borne by the utility infrastructure. As with any “Commons”, there will come a day when the resource can no longer be sustained.

These effects are both complicated and amplified by the various state level Renewable Portfolio Standards (RPS) and the Production Tax Credits (PTC) currently in force or pending.

Renewable Energy System Integration Costs.pdf

Sat, 21 Nov 2015 07:47:33 -0700
Wind Load Factor I love Wind!

Wind is good, anytime…anywhere! I like how they look and I like what they do.

But, have you ever noticed that all the success claims relate to how much wind capacity has been installed, rather than how much power that has been generated.

To illustrate, here’s some recent data on installed capacity:

There is some information available on wind energy penetration into the overall electricity consumption. As can be seen from the chart shown below, the U.S., as a point of comparison indicates that wind accounted for just under 5% of electricity consumption in 2013, an approximate 4x increase over 2006.

In terms of Climate Change impact and specifically in terms of the CO2 emissions profile, load factor is more interesting.Wikipedia provides some wind data by country, tabulated below.

The data suggests that load factors typically vary between 20% and 30%.No surprise here.Most of these wind projects tend to be driven by first cost and today these wind assets are backed-up by natural gas-fired, simple-cycle gas turbines to manage the intermittent wind resource. These types of simple cycle units are required by the EPA New Source Performance Standard to not exceed 1100 lb-CO2/MWh.

The combined effect of 30% at zero lb-CO2/MWh, plus 70% at 1100 lb-CO2/MWh, would deliver 770 lb-CO2/MWh in the best case, but some of these simple cycle units operating at part or varying load struggle to meet 1100 lb-CO2/MWh and at a 20% load factor, that combination would yield a value closer to the combined cycle CO2 threshold without abatement of 1000 lb-CO2/MWh.

Wind Load Factor.pdf

Wed, 23 Sep 2015 08:35:37 -0600
The EPA's Clean Power Plan - 2015 What does a 32% reduction in power plant CO2 emissions by 2030 that really mean?

Let’s start with the data.

The U.S. Energy Information Agency (EIA) has published its “Analysis of the Impacts of the Clean Power Plan”, and within it, It has evaluated a number of scenarios and included the relevant 2005 and 2013 historical data used as the referenced starting points.

The scenarios of most interest include the Reference Case (AEO), as published in the Annual Energy Outlook 2015 (AEO2015), and the Base Policy (CPP) reflecting the full implementation of the Clean Power Plan.

Two sensitivities for these cases are presented; the High Economic Growth (AEOHEG), and the High Oil and Gas Resource (AEOHOGR). These sensitivities are shown for both the AEO Reference Case and for the CPP Policy Case. The combination of High Economic Growth AND High Oil and Gas Resource is not presented. The red numbers in the following tables are my best guess at the combined effects.

The 2005 reference value for Electricity Production is 2416Mt. Therefore, a 32% reduction would mean a target of 1643Mt by 2030. (Mt) is the abbreviation for million metric tonnes (2416Mt = 2.416Gt).

The base CPP case allows existing coal-fired plants to operate at a higher utilization rate, rising from a low of 60% in 2024 to 71% in 2040.

There is a Policy Extension case (CPPEXT) which extends CO2 reduction targets beyond 2030 and assumes a further reduction in CO2 emissions from the power sector to 45% below 2005 levels by 2040. The 2040 target for the Policy Extension case is 1329Mt and is presumed to be met with by a further shifting of power generation from coal to natural gas.

Here are the 2030 values, presented in the AEO2015 along with the new target just announced by President Obama. I have also presented the AEO 2040 cases.There are no 2050 cases in the AEO2015.

CO2 Emissions from Electricity Production - Values are Million metric tonnes (Mt)

Does a 32% reduction in Electricity Production by 2030 get us to a 2°C/450ppm target by 2050?

Firstly, no one is asking this question.

The following charts were presented by the EPA at a Supercritical CO2 Conference in 2014.They are the results of a road-mapping exercise that looked at the CO2 emissions issue through 2050.

Source: DOE SCO2 Conference 2014, as presented by EPA

The Baseline Scenario lines up with the roughly 5600 – 6000Mt levels for the U.S. baseline for all sectors, depending on which data set is being used. The Baseline Scenario is ~2200Mt level for Electricity Production and shows an early 10% decline in 2030, but then remaining relatively constant at 2000Mt through 2050.

The 50% reduction strategy indicates the 5600Mt dropping to 4400Mt by 2030, and to just under 3000Mt by 2050. The previously reported MIT-Mike Orcott analysis indicated a U.S. goal of 1300Mt, shown as 1.3Gt, would be required to achieve a 2°C/450ppm target. This seems consistent with the 50% CO2 Reduction road-mapping data.

In the 50% reduction scenario, the Electricity Production contribution is 1000Mt by 2030, dropping to 200Mt by 2050. The 2030 value appears to be a 38%, “fair share” value for Power Generation, while the 200Mt in 2050 indicates a disproportionately larger contribution from Electricity Production, consistent with its ability to capture carbon at its large point sources. On a proportionate basis, CO2 from Electricity Production in 2050 might be 500Mt.

These two values, 200 and 500Mt, represent the 2050 target range for Electricity Production to achieve its share of a 2°C/450ppm target.

The Obama 2015 goal of 1643Mt by 2030 is not materially different from the two CPP sensitivity cases, shown either individually, or with the combined effect.And, it does not matter whether the 2030 or the 2040 comparison is used. In all but the Policy Extension case, the emissions from the Electricity production is still 3-4X what would be required to achieve a 2°C/450ppm target by 2050.

The Policy Extension case, which presumes a continued shift from coal to gas but lacks specifics, is still 3X what would be required. Some would call this “magical thinking”.

So, the short answer is that 32% by 2030 is a start, but these actions alone and their simple extensions are not nearly good enough!

The Policy Extension is almost entirely dependent on a further shift from coal to natural gas generation, plus added renewables. As reported earlier, the effect of the coal-to-gas shift may be overstated. In addition, all these cases seem to ignore any shift to electric vehicles and the attendant increase in power generation required to support it.

Simply stated, in order to achieve a 2°C/450ppm 2050 goal, we have to address the emissions from NGCC power plants. We can certainly apply CCS to NGCC power plants before 2030, but the EPA has chosen to defer this opportunity through their 1000 lb- CO2/MWh emissions standard threshold, which allows NGCC power plants to operate completely unabated.

The most direct approach would be to apply CCS to NGCC and use the lower cost of natural gas to offset the added cost of CCS. This approach would not require an entirely new power plant concept, as is the case with IGCC or whatever, and we would actually then be on the CCS learning curve.

It appears that the EPA is avoiding the “opportunity” to implement CCS by setting the regulations at a level that does not require it, banking on fuel-switching to make progress. And, yes, progress is being made, but we are knowingly not on a trajectory that will deliver 2°C/450ppm by 2050.

I think that this is why all the targets are expressed as percentage reductions rather than progress toward a defined end goal.

EPA Clean Power Plan 2015 Rev4.pdf

Wed, 23 Sep 2015 08:24:54 -0600
Impact of Fuel Switching on CO2 Emissions You may recall all the hoopla surrounding the reduction in the U.S. CO2 emissions in 2013, coincident with new-found shale gas resources. We had turned the corner on CO2 emissions…a true eureka moment!

This is what the U.S. Energy Information Agency published at the time. The 2416Mt and the 2053Mt values still exist in EIA’s May 2015 Analysis of the Impacts of the Clean Power Plan.

Note: million metric tonnes (Mt) is sometimes abbreviated as MMmt as in the graphic above.

On July 21, 2015, Nature Communications published a fascinating analysis of U.S. CO2 emissions during same 1997-2013 period. The study was led by University of Maryland’s Klaus Hubacek in cooperation with Steven Davis, UC Irvine; Kuishuang Feng and Laixiang Sun.

Here is the graphic that they published, summarizing their findings. Fuel mix is the orange bar:

A few of their conclusions:

“Commentators in the CO2 scientific community and media have linked the two trends, celebrating the climate benefits of the gas boom…..

Recently, the Third National Climate Assessment of the United States Global Change Research Program also adopted this conclusion, stating that the decrease in US CO2 emissions was ‘largely due to a shift from coal to less CO2-intensive natural gas for electricity production’.

Yet, despite potentially significant implications for US climate and energy policy, there has been no quantitative analysis of whether the gas boom and changes in the fuel mix of the power sector are indeed driving the decrease in US CO2 emissions…..

….We conclude that substitution of gas for coal has had a relatively minor role in the emissions reduction of US CO2 emissions since 2007.

…. The large decrease (9.9%) in US CO2 emissions between 2007 and 2009 was primarily the result of the economic recession…

……the modest effect of changes in the fuel mix of the energy sector on emissions in recent years suggests that further increase in the use of natural gas may be of limited benefit in decreasing emissions. This is because barring technology-specific policies (for example, Renewable Portfolio Standards); recent studies have shown that gas does not substitute for coal only…

….. Growth of emission-free technologies such as solar, wind and nuclear energy is also limited while gas is cheap. In these studies, future increases in natural gas use act to both reduce domestic coal use and slow the growth of renewable energy, resulting in little net change to cumulative CO2 emissions.

…..a growing number of studies also show that increased leakage of methane from new natural gas infrastructure can offset CO2 reductions relative to coal…

…..Decreases in residential gas prices may lead to rebound effects if people spend some of the money they saved heating their home on carbon- and energy-intensive goods….

…..And finally, decreased domestic demand for coal has enabled an increase in US coal exports to eager and growing overseas markets.”

The new EPA Clean Power Plan is largely built on fuel switching and renewables deployment.

The article may be found here:

Impact of Fuel Switching on CO2 Emissions Rev3.pdf

Wed, 23 Sep 2015 08:12:38 -0600
Competitive Positioning - Pending New EPA Standards There is ample information on various DOE websites defining cost and performance baselines for the various types of power plant options currently in today’s available mix. I used DOE/NETL- Baseline 341/082312, August 2012, and DOE/NETL- Baseline 2010/1397, November 2010.

The competitive scenario is totally dictated by the 1000 lb-CO2/MWh emissions standard promulgated in the EPA New Source Performance Standard (NSPS), first released in 2014. Under that requirement a new Supercritical Pulverized Coal plant (SCPC) with Carbon Capture (CCS), Case 12, is competing against a Natural Gas Combined Cycle (NGCC) plant without CCS, Case 13.

I use the term “competition” loosely, because given this threshold level; it is hardly a fair fight. How un-level is it?

Grossly unlevel.

Look at Cases 12, the SCPC w/CCS and compare it to Case 13, the NGCC w/out CCS.

  • The SCPC w/CCS plant is 5X the first cost
  • And, the efficiency of an SCPC w/CCS is ½ at 28.4% vs. 50.2%
  • The Levelized Cost of Electricity (LCOE) for the NGCC without/CCS is ½ that of the SCPC w/CCS and this is based on $6.13/mmBtu cost for natural gas.
  • If the current price for natural gas is considered, the LCOE is 1/3 that of the SCPC

And, you wonder why gas turbines have had record levels of sales??

There are some who would have you believe that this is purely the result of low gas prices, and that this is “just the market place exerting itself”. This is hardly the case. Yes, the price of gas is a factor, but the real driver is that CCS is required in Case 12, but not for Case 13. Yes, the price of natural gas is a huge accelerant, but still that of an accelerant.

The Coal Industry has been spending its political capital trying to make the NSPS threshold simply go away, in which case the competitive comparison would be Case 11 vs. Case 13. In such a comparison, the first cost for the SCPC is 3X and the efficiency at 39.3% vs. 50.2%.

The Coal Industry might want to consider a strategy to push full CCS, which would then position their Case 12 against the NGCC Case 14. The first cost difference would be 2.5X and the efficiency would be 28.4% for the SCPC w/CCS vs. 42.8% for the NGCC w/CCS. Not pretty, but they could actually have the environmentalist community on their side.

The recently announced Clean Power Plan pretends to be agnostic on how each of the states reach their assigned targets, but behind the targets themselves is the built-in assumption that NGCC’s without will provide a ~70% contribution, which would then be driven by the same 1000 lb-CO2/MWh threshold.

The unanswered question in all of this is whether or not this 1000 lb-CO2/MWh threshold, either explicit or implied, reaches the presumed target of 2°C/450ppm. It should be noted that neither the NSPS nor the CPP mention a target, let alone a target of 2°C/450ppm.

It is hard to reach a target if you don’t have one, but on second thought it is actually easier to reach a target if you don’t have one!

Current Competitive Positioning - Rev4.pdf

Wed, 23 Sep 2015 08:08:10 -0600
The CO2 Budget - Let's Talk Numbers The recent Intergovernmental Panel on Climate Change (IPCC) issued its Annual Review - AR5 with a graphic that may help frame the Climate Change issue.

The notion of a CO2 Budget has always existed, but the published information is usually expressed in percentages, or a 2°C/450 ppm temperature/CO2 concentration combination that creates a scientific aura around the issue.

This aura allows cover for those who hide behind the “I am not a scientist” mantra.

Since many of those in “hiding” usually profess great competency in planning and budgeting, one would think that the notion of a CO2 Budget would be in their “wheelhouse”.

The following table is extracted from BP’s Annual Statistical Review of Worldwide Energy – 2015, available as a downloadable Excel spreadsheet…..thank you BP. The full table provides a consistent basis for the annual CO2 Emissions by country back through 1965. I have extracted the most recent data for the U.S., China and India to help put this budget into perspective.

The percentages are the 4-year compounded growth rate of the total.

The big take-away is that the world released 35.5Gt (35,498.7 Mt) of CO2 in 2014, increasing at almost 1.88% per year, averaging the averages. At this rate we will reach the 2900Gt budget in 2035 and on an increasing trajectory, headed toward 69Gt by 2050.

The following graphic indicates a 58Gt, 6°C trajectory, which we are currently exceeding, as well as 40Gt and 16Gt trajectories associated with 4°C and 2°C, respectively.

To reach the 16Gt level by 2050 requires a 2.19% per year reduction and, of course, would be on a declining trajectory. The U.S. component of this 16Gt target is shown as 1.3Gt. The power generation component of this 1.3Gt U.S. total is 0.5Gt, or 500Mt, based on its historical 38% contribution.

It should also be noted that The U.S., China and India, the three biggest offenders are responsible for 50% of the CO2 released.

These numbers are useful in understanding and analyzing the various regulatory and administrative initiatives currently being discussed.

The CO2 Budget - Lets Talk Numbers Rev3.pdf

Wed, 23 Sep 2015 07:53:34 -0600
CO2 Waste Disposal Fee This is where we are on the atmospheric CO2, according to the recent IPCC 5th Assessment Report.

The worldwide CO2 emissions in 2013 were 36.1 Gt. The chart shown below models a full spectrum of scenarios included in the assessment along with a 2014 estimate. Currently, we appear to be tracking on the RCP8.5 trajectory.

This is where that CO2 came from in 2011 and an associated forecast:

The U.S. emissions from Electric Power were 2023 Mmt (2.023 Gt) in 2012. The overall U.S. total was 6363 Mmt (6.363 Gt) emitted, but a 979 Mmt (0.979 Gt) credit for land use is an applied, yielding a U.S net of 5383 Mmt (5.383 Gt).

Power plants accounted for 37.5% of the net, with the land use credit or 31.8% of the overall CO2 produced.

There are those who advocate that renewables are the way forward, and they are correct, but appreciate neither the scale of the problem, nor the path toward that realization.

Renewables represented less than 2.0% of the world energy consumption in 2012, while the U.S. alone is slightly higher at 2.2%. Natural gas and coal represented 50% of the U.S. total.

We have to deal with these emissions as we transition to the renewables future, and we have a long way to go.

The gas industry and their advocates have “sold” the notion that natural gas is that “bridge” and therefore, the answer.

Natural gas is a fuel.When burned in a power plant it produces huge amounts of CO2, albeit “½ of coal”, but huge amounts nonetheless.

The U.S Energy Information Agency produced a generation mix forecast for their Annual Energy Outlook 2014. Their Reference Case scenario shown below and indicates coal-fired resources producing approximately 1,600 billion kilowatt-hours, with natural gas-fired units producing at, more or less the similar level.

There are High & Low Resource companion cases, as well.

The following table approximates the Gt CO2/year emissions by type of fuel and in total for each of the three cases. It also indicates the power produced for each case.

The estimates include the EPA emissions targets of 1000 lb-CO2/MWh for Natural Gas Combined Cycle Power Plants and 1100 lb-CO2/MWh for Simple Cycle variants, as well as the assumption that these NGCC power plants are “half of dirty coal”. Coal is therefore approximately 2000 lb-CO2/MWh.

In all three cases, the CO2 emitted remain above 2.0 Gt per year in 2040, under the current & proposed regulatory framework.

If you believe the Carbon Conundrum, as presented below, the U.S. needs to limit CO2 output to 1.3 Gt in total in order to meet the 2°C/450 ppm target according the Mike Orcutt, as published in the M.I.T Technology Review.

Power Plants represented 37.5% of the net CO2 output in 2012. At this rate, their 2040 contribution would need to be 0.5 Gt.

To make the 0.5 Gt target with any of these EIA 2040 projections, power plants of all types need to capture approximately 80% of their CO2 emissions.

The “bridge” to a renewables future is Carbon Capture & Storage, not natural gas.

McKinsey Cost Curve, published in 2007, provides a useful roadmap for action. The curve presents a set of actions available to reach 450 ppm, including coal-to-gas conversions, CCS and nuclear. It is important to notice that the magnitude of these other options dwarf the coal-to-gas shift.

Unfortunately, the current/proposed EPA Power Plant Standards, as described below, have effectively eliminated CCS and nuclear from consideration.

The IPCC AR5 report specifically indicates that many scenarios cannot reach 450 ppm CO2 equivalent concentration by 2100 in the absence of Carbon Capture and Storage (CCS) and nuclear, reinforcing what the cost curve indicates.

We must address two overriding issues in order to meet any kind of Climate goal assuming there is one:

  • Any regulatory standards must be technology neutral and not distort the competitive balance with “pet ideas” or favored solutions, nor provide dispatch order preference. The market mechanisms must be allowed to work without biasing outcomes.
  • We need to establish a price/cost for CO2. Today, the price/cost is zero

There is a built-in assumption that if the EPA is involved, their requirements are likely to be way too stringent on behalf of the public interest. In this case, however, the EPA is implementing a set of regulations that appear to be little more than self-serving.

Based on the emission thresholds established in their recent regulatory initiatives, the EPA, with the help of “the Gas Team”, has made it clear that they have no interest in capturing CO2, most likely because they have no viable plan to deal with CO2, if captured. Instead, the EPA has written a standard that is so obviously skewed toward natural gas-fired units without CCS, that they have effectively made their CO2 problem “disappear”. They have done very little about our CO2 problem.


  • The EPA levels of 1100 & 1000 lb-CO2/MWh for Natural Gas Simple and Combined Cycle gas turbine power plants respectively, allow all these plants to be built without doing anything about their CO2 emissions.
  • These regulatory levels are the same levels of the current technology level Natural Gas powered units. They offer that these levels are consistent with the “Best Available Commercial Technology” or BACT, but this is the same thing as saying “Business as Usual”.
  • Under these standards, a coal-fired power plant would have to be equipped with CCS and would be 4-5x more expensive with half the efficiency of a natural gas-fired power plant without CCS, completely distorting any semblance of a “level playing field”. The Gas Team likes this part.
  • The EPA would have you believe that the price of natural gas is the underlying cause of the shift away from coal. Although convenient in deflecting criticism, such claims are disingenuous. The regulatory thresholds are the principal drivers.
  • Neither the EPA New Source Performance Standard and nor its companion Clean Power Plan make mention of Climate Change, except in the abstract.
  • There is no notion of a “CO2 target” to act as a driving force for improvement.
  • In addition, there is no mechanism to establish a cost for emitting CO2.
  • Unfortunately, this “Business as Usual” approach, is only dressed up to look like action and progress, but in that process, the approach is completely undermining the development of CCS and nuclear technologies, the very technologies essential to meeting a 2°C/450 ppm target .
  • There is always discussion about driving the cost down with learning curve effects….We are not on the learning curve!

There is broad consensus among those that take Climate Change seriously that one of the most important actions we can take is to establish and allocate the true cost associated with CO2 emissions.

Two commonly discussed options include:

  • Cap and Trade
  • Carbon Tax

Cap and Trade comes in two parts. The “Trade” is easy. The “Cap” is arbitrary, political and given to political influence. Does anyone really trust politicians to set “Caps” objectively and in a timely manner?


There are issues with the Carbon Tax approach, as well:

  • What do we call it… and is it a “tax”?
  • How is the tax established? By whom?
  • Where in the process is the tax assessed?
  • In addition, what do we do with the money?

The “Fee & Dividend” is one Carbon Tax approach. This concept returns any tax proceeds, minus any administrative costs, back to individuals and businesses in the form of a dividend or rebate. Politicians favor this concept for the obvious reasons. Some variations on this theme can also include a disproportionate re-distribution of wealth element.

Unfortunately, the proceeds in the “Fee & Dividend” concept are not used to address the problem. The rebate is not an incentive to drive conservation efforts and in some cases may have the reverse effect. At best, the approach relies on some sort of politically contrived fuel price to influence behavior, but then only indirectly.

The approach is too complicated and requires political involvement to implement. We need to use the money to fix the problem.

I would like to propose an approach where the carbon tax is actually used address the problem directly. The principal elements of the approach are:

  • Implement a “CO2 Waste Disposal Fee” that actually reflects the cost of dealing with the CO2 life cycle.
  • Use the proceeds to build and operate CO2 pipelines to remote locations for underground storage in perpetuity.
  • Federal Government assumes the role of Operator in Perpetuity using some form of a “Cemetery” business model.
  • The “CO2 Waste Disposal Fees” are assessed where the CO2 is generated, i.e., the power plant or refinery. These organizations have well document and proven cost models that can serve a basis to objectively assess cost and needed cost recovery fees.
  • The costs will be absorbed into the energy price, either in raw or converted form, and thereby influence both investment decision and consumer choice.
  • “CO2 Off-take Agreements” for productive use of CO2 are encouraged and become credit to system cost.
  • There is no such thing as “Clean CO2”. It is just CO2. The Waste Disposal Fee has to be fuel agnostic…no favorites allowed.
  • The Renewable Energy Portfolio and accompanying dispatch order preferences must be earned in the competitive process, without subsidies or preferences, allowing load factors to be sorted out in the market place.

Professor David Victor, University of California made the comment:

“We are the first generation to experience the effects of Climate Change…..…..and, the last generation to be able to do something about it!”

I believe that this approach is where we will end up. The only question is how long will it take us to get there and how many other approaches we will have tried first.

CO2 Waste Disposal Fee.pdf

Tue, 16 Dec 2014 11:38:55 -0700
The EPA’s Clean Power Plan……a Good Start’s-clean-power-plan……a-good-start It seems a foregone conclusion that we’re going to go with the “natural gas is a bridge fuel” logic, because it fits the current political narrative. I’d like to put this into perspective.

This approach puts us on the “Coal-to-gas shift” initiative, underlined in red, below:

Remember the McKinsey Cost Curve….right? Circa 2007! A little dated, but then again, not much has changed since 2007. I have always liked this representation, because it is simple.

The chart outlines a set of possible actions that could be deployed to reach a presumed 450 ppm atmospheric CO2 concentration target, the consensus, thought to be, threshold needed to limit the temperature increase to not more than 2°C.

The width of the bars in this stacked bar chart represents the magnitude of the contribution for each of these potential initiatives in GtCO2e (giga-tonnes of CO2 equivalent) per year in 2030. The height of each bar represents the cost, in euro, per tonne of CO2e. These defined actions are arranged by increasing cost. The negative cost actions on the left side of the chart are efficiency and conservation initiatives. Added cost initiatives are to the right.

There are two disturbing things about this chart:

  1. The first is how miniscule the positive effect of the Coal-to-gas shift is, underlined in red….
  2. And the second is how large the bars are for the Carbon Capture & Storage (CCS) and nuclear actions, seen as essential to reaching the 450 ppm target and underlined in green, and also the ones negatively affect by current policy.

The recent draft release of the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report, Summary for Policymakers, concludes that there are very few options to reaching 450 ppm that don’t include CCS.

We need all of these actions, but right now, we have set the rules up so that we’re mostly getting the coal-to gasinitiative for new plants, compliments of the EPA and their supporting gas team. And, in that process we are killing the others. The rules have so distorted the competitive balance, that these other initiatives are no longer being pursued in any meaningful way.

I scaled these negative effects on CCS and nuclear and they are about times (25x) larger than that of the gains that could be realized from the coal-to-gas shift. OK, the Coal-to-gas shift will become larger as we build more Natural Gas Combined Cycle (NGCC) plants, but that contribution alone does not get us where we need to be.

The problem is in thinking that natural gas is the so-called “bridge”. Natural gas is the fuel. The “bridge” is CCS.CCS needs to be implemented across the board, and implemented without playing favorites. We also need to develop the full cost accounting tools to inform good policy decisions.

The Carbon Capture Conundrum, published by Mike Orcutt in 2012 offers another simplified explanation of the opportunity.The worldwide CO2 emissions are running at 31Gt /year and the consensus opinion is that the Business as Usual trajectory will reach 58 Gt by 2050, an increase of 27 Gt/year.

The Carbon Conundrum calls for a reduction of 42Gt in total from that Business as Usual trajectory with a U.S. contribution of a 4.10Gt reduction.

    Mike Orcutt – M.I.T. Technology Review Aug. 2012

On June 2, 2014, the EPA released their draft ruling for CO2 emitted from existing power plants, referred to as the Clean Power Plan. It calls for a 30% reduction of CO2 from existing power plant sources, and is said to be complimentary with the previously announced NSPS for new power plants.

Coincidently, on June 9, 2014, the Energy Information Agency (EIA) also released a set of projections, as shown below.

        Source: U.S. Energy Information Administration, Monthly Energy Review, September 2013, and the Annual Energy Outlook 2014

These EIA projections, as stated, do not specifically include the effect of EPA’s new ruling, but several scenarios explore the effect of a $10 and $25 Energy-Related CO2 fee, as well as fuel cost and availability differences.

The 2005 U.S. Power Sector CO2 emissions baseline for the new ruling is 2.40Gt (2400 million metric tonnes - red vertical line), or 40% of the 6.11Gt U.S. total, a number published elsewhere.The 30% reduction from this 2.4Gt level required by the Clean Power Plan is a target reduction of 0.72Gt. If this 0.72Gt represents that same 40% contribution, the overall U.S. reduction, assuming all sectors performed as well as the power sector, would be 1.80Gt vs. the 4.10Gt Carbon Conundrum target.

During the second commitment period of the Kyoto Protocol, the parties committed to reduce GHG emissions by at least 18 percent below 1990 levels in the eight-year period from 2013 to 2020. The 1990 U.S. CO2 emissions were 5.11Gt, of which 1.82Gt were from power plants. The resulting Kyoto targets (blue horizontal line) would then be 4.19Gt in total and 1.50Gt (1500 million metric tonnes) for power plants, assuming their same contribution.....the EIA GHG25 scenario at $25/tonne of CO2.

To achieve the overall reduction of 4.10Gt by 2040 with a 40% power-sector contribution rate, the U.S. power sector would need a 1.64Gt reduction and closer to 2.00Gt if the other sectors underperform. To achieve that 2.00Gt target reduction, the power sector would have to reach a 0.40Gt level (400 million metric tonnes - green horizontal line) and, per the EIA chart; this would imply some form of CO2 fee…. also on the EIA GHG25 trajectory.

In short, the EPA’s plan is a good start, but it is only a start.

It should be recognized that these ruling, while a good start, are at the same time, seriously undermining both nuclear and CCS initiatives.

Wed, 02 Jul 2014 14:21:04 -0600’s-clean-power-plan……a-good-start
EPA New Source Performance Standards - 2014 The EPA has issued a revised Standard of Performance for Greenhouse Gas Emissions from New Electrical Generating Units, still subject to a comment and review period.

The basic standards put forth are as follows:

  • Coal-fired units – 1,100 lbs-CO2/MWh, over a 12-month operating period;
  • Coal-fired units that choose to average their emissions over a seven-year period – 1,000 to 1,050 lbs-CO2/MWh, over that 84-month operating period;
  • Gas-fired turbines larger than 850 mmBtu/hr – 1,000 lbs-CO2/MWH; and
  • Gas-fired turbines smaller than 850 mmBtu/hr – 1,100 lbs/MWh

The 850 mmBtu/hr is the thermal input and defines the size of the power plant. The 1000-1100 lbs-CO2/MWh is the emission standard for that size. The actual rated output of the power plant is a function of the fuel type and its efficiency.

This is how the suggested standard translates into actual power plant sizes for the various fuel and power plant types:

This is a summary of the key findings and assumptions embodied within the proposed ruling:

The proposed ruling:

  1. The basic ruling puts forth the notion of separate standards for coal vs. natural gas fueled power plants. There is no logic offered as to why this determination was made, but it seems clear that this was a concession to the coal industry.
  2. And that, simple-cycle gas turbines can be applied, without abatement, to back up wind and solar renewable resources.
  3. The ruling argues that partial Carbon Capture & Sequestration (CCS), as applied to coal fired power plants, is “proven” by the five demo projects cited in the background information provided.
  4. It also argues that imposing CCS on coal plants won’t affect consumer electricity pricing because no one is building coal plants anyway.
  5. It argues that since there are no demo projects that apply CCS to natural gas combine cycle power plant (NGCC), CCS for gas is therefore unproven and since NGCC-CCS is “unproven”, EPA cannot mandate its use.
  6. They argue that mandating CCS on coal will help bring the technology into use, although no one is expected to use it, per point 4 above.

The reality:

  • There is no difference between CO2 from a NGCC or coal power plant…it’s just CO2.
  • The same Post Combustion capture technology can be applied to either NGCC or coal.
  • Yes, there are cost differences between applying CCS to a coal plant vs. a NGCC plant. These differences are associated with the CO2 flue gas concentration. Coal flue gas is typically 12% CO2 and NGCC flue gas is 4% CO2.
  • The de facto standard at the local Public Utility Commission (PUC) has been Coal-CCS vs. unabated NGCC for the last 5-years.
  • There are no new coal projects, other than those few subsidized Demo Projects mentioned, and no new projects in the planning stages.
  • We’re not on the CCS “learning curve”, nor are we on the trajectory to achieving the 2°C/450 ppmv atmospheric CO2 target. It is not even clear if this is the target.
  • The ruling does not provide any mechanisms/platforms to establish a cost for CO2 emitted.

The irony:

  • If coal had not proceeded with demo projects and therefore were to fall into the “unproven” category, would coal still have had to deploy with CCS?
  • And, why would anyone spend money to establish that NGCC-CCS is viable, when that would then set a new “proven” standard, obligating its use?
  • There is a complete absence or any mention of the actual climate change targets in the proposed ruling. There are references to climate change, but only in the abstract.
  • The BACT -Best Available Control Technology or BSER-Best System of Emission Reduction bases for this ruling are, by definition, a BAU-Business as Usual approaches, because they apply a commercial availability/readiness test to their implementation.
  • The term BSER was used to cover the combination of power plant and CCS, as applied to NGCC. This is an artificial point of difference between CCS applied to coal vs. gas to affect separate “readiness” outcomes.

Right now, the debate centers around whether Coal-CCS has been demonstrated enough, or even at all. The coal industry is suggesting, not. And, the House Energy & Commerce Committee is investigating the EPA on that determination.

And, the U.S. House of Representatives is also offering its own version of any ruling that seems to be supportive of the coal industry and with what appears to be an implementation in 2050, maybe. They ask that:

  • Best System of Emissions Reduction (BSER) be demonstrate within coal category as:
    • One continuous 12-month run ofby each of (6) separateunits at (6) separate locations, that,
    • Collectively represent the operating characteristics ofdifferent US locations,
    • Each of which, must operate on a full commercial basis for an entire 12-month period.
  • And, that results from demonstration projects cannot be used in demonstrating the BSER
  • And, that there be a separate sub-category for (3) separate units operating on coal with average heat content of 8300 Btu/lb. (lignite)

    It is also clear that a couple of factions in this debate are using to current low gas price to deflect criticism of the ruling itself.

    Make no mistake.

    Any root cause analysis on the negative impact on the coal industry will focus squarely on the EPA ruling, not the price of natural gas. Yes, the price of natural gas has had an enormous impact, but it has been that of an accelerant, not the root cause.

    There are four things that are really clear to me:

  1. There is no “forcing function” applying pressure to reach a climate change target…there is no target or cost associated with emitting CO2, and the standard, such as it is, is “Business as Usual”, so how can there be any pressure applied? No one is asking, “If we do it this way, do we achieve the target?”What target?
  2. The EPA, through this ruling, gives every impression it does not want to capture CO2…..probably because they have no clue on how they would dispose of it, once captured.It is the “you break it, you own it issue”.They don’t want to own it. This ruling insures they do not capture CO2, yet attempts to create the appearance of action or progress on the climate issue.
  3. Because of this ruling, CCS is on life support, with no one is really advocating for its use. It is still the only approach that can deal with CO2 at the scale of the problem, however. It will return to favor, someday and likely emerge first in China.
  4. The outstanding growth in gas turbine industry sales in support of U.S. NGCC deployment will continue, uninterrupted for the foreseeable future.

Corrected version

Original published Turbomachinery International Blog March 20, 2014

Wed, 02 Jul 2014 14:15:32 -0600