New Carbon Dioxide Emissions Limits Cost Nothing and Offer No Benefits, Says EPA

Griffin024

Today the Environmental Protection Agency issued proposed new regulations limiting the emissions of carbondioxide from new electric power generation plants. The EPA press release states:

Under today's proposal, new large natural gas-fired turbines would need to meet a limit of 1,000 pounds of CO2 per megawatt-hour, while new small natural gas-fired turbines would need to meet a limit of 1,100 pounds of CO2 per megawatt-hour. New coal-fired units would need to meet a limit of 1,100 pounds of CO2 per megawatt-hour, and would have the option to meet a somewhat tighter limit if they choose to average emissions over multiple years, giving those units additional operational flexibility.

Since current coal-fired electric generation plants emit about 1,800 pounds of CO2 per megawatt-hour, the new regulations would essentially outlaw the construction of new conventional coal-fired plants. Not to worry, says the agency in its regulatory impact statement:

Under a wide range of electricity market conditions – including EPA's baseline scenario as well as multiple sensitivity analyses – EPA projects that the industry will choose to construct new units that already meet these standards, regardless of this proposal. As a result, EPA anticipates that the proposed EGU New Source GHG Standards will result in negligible CO2 emission changes, energy impacts, benefits or costs for new units constructed by 2020. Likewise, the Agency does not anticipate any notable impacts on the price of electricity or energy supplies…

These proposed EGU New Source GHG Standards is not anticipated to change GHG emissions for newly constructed electric generating units, and is anticipated to impose negligible costs or monetized benefits. EPA typically presents the economic impacts to secondary markets (e.g., changes in industrial markets resulting from changes in electricity prices) and impacts to employment or labor markets associated with proposed rules based on the estimated compliance costs and other energy impacts, which serve as an input to such analyses. However, since the EPA does not forecast a change in behavior relative to the baseline in response to this proposed rule, there are no notable macroeconomic or employment impacts expected as a result of this proposed rule.

Surely if there are no costs, then there must be some benefits accruing to the public from the new rules, right? Well, no. As the agency impact statement notes:

…the proposed rule is anticipated to yield no monetized benefits and impose negligible costs over the analysis period.

That's right - no costs and no benefits. Just new regulations.

Comments

[Fist of Etiquette]

That's right - no costs and no benefits.

That would actually be the best outcome you could hope for in the regulatory environment we've set up for ourselves: regulations that exists solely to keep bureaucrats employed.

[#]

It's a good thing natural gas is so cheap right now, so that market forces are naturally shifting from coal to gas. But that may not alwasy be true. If coal otherwsie becomes more eocnomically viable again, that's when the cost of these regulations get felt, but no one will realize that rsing electricity prices are due to the defacto ban on coal.

[Mickey Rat]

"If coal otherwsie becomes more eocnomically viable again,..."

That's almost certainty. Coal is the one fossil fuel the USA has the lead in untapped reserves. It's not a question of if but when.

[DesigNate]

Hey Ron, can you explain to me why CO2 is considered a pollutant, at least by these people?

[Stormy Dragon]

If you release a big enough cloud of CO2, it would asphixiate everyone in the area, so there's obviously some point at which CO2 should be considered a pollutant, even if it's at levels far far higher than what the EPA is proposing.

[Marshall Gill]

Holy Science this is epic level derp, even for you! A big enough cloud?

Of course the air that you exhale should not be considered a pollutant. The things you say on the other hand....

[Stormy Dragon]

Yeah, let's start drinking raw sewage too. After all shit comes out of our bodies, so apparently it can't be considered pollution.

[Marshall Gill]

So "the air you exhale" is the same as "raw sewage"? Because I said "if it comes out of our bodies it can't be considered pollution"? Oh, no I didn't, not at all. You certainly got the voices in your head with that one!

I mistakenly assumed that you were making some attempt at argument. I should have known better after the "If there is enough to deprive you of oxygen you will asphyxiate so it is pollution" drivel.

[Stormy Dragon]

So "the air you exhale" is the same as "raw sewage"?

No. Nor is "the air you exhale" the same as the output from the smokestacks of a powerplant. If you're not trying to argue that things that come out of our body can't be considered pollution, how is human respiration relevant at all?

[Mr Whipple]

Nor is "the air you exhale" the same as the output from the smokestacks

The CO2 is the same, isn't it? Or is there a different type of CO2 that comes out of powerplants?

The derp is strong in this one.

[Terr]

Everything other than pure oxygen (not greater than atmospheric pressure) is a pollutant!

[Paul.]

Pure oxygen is a pollutant. Oxygen toxicity.

[Terr]

Isn't that at pressures higher than 1 atmosphere?

[CatoTheElder]

Animals are adapted to breathe dilute oxygen, not pure oxygen. Any emission other than 21% O2, 78% N2, and the appropriate fractions of trace gases (including about 0.3% CO2) is a "pollutant".

[SomeGuy]

what if you lite a fire in a pure oxygen world? how would plants survive!! For the Plants!

[Paul.]

Stormy, all poison is in the dose. Therefore Oxygen is a pollutant, so is water.

[Stormy Dragon]

Hence "even if it's at levels far far higher than what the EPA is proposing".

[Endless Mike]

So does that mean that the EPA should regulate EVERYTHING?

[Stormy Dragon]

No, the EPA shouldn't exist at all. Pollution is ultimately a form of trespass and should be handled like other forms of trespass.

My point, though, is that the arguments against the EPA are often based on the assumption of some sort of right to spew things into the air or water, usually backed up by an appeal to convenience.

[PM]

"often"; "assumption"; "usually"

[weasel words]

Particularly in light of the fact that no one outside of your head articulated that position in any way, shape or form.

[BlueBook]

Humans cannot survive in a vacuum, therefore nothingness is also a pollutant. Also, just about any kind of energy (radiation) can be harmful in a large enough dose, so energy is a pollutant. Basically, the whole universe is a pollutant, and should be outlawed immediately. For the children.

[Mr Whipple]

I polluted in my pants.

[Sy]

Yeah, CO2, hell almost any gas, does not secrete into homogenous "clouds".

[Greg F]

..so there's obviously some point at which CO2 anything and everything should be considered a pollutant...

There ... Fixed it.

[DesigNate]

What the...I don't even...huh?

Seriously, in what way could a cloud first of all be released and second of all completely block all the oxygen in the area.

[CatoTheElder]

If only we could popularize the slogan:

"CO2: it's what plants crave."

[The Knuckle]

Does it have electrolytes?

[Acosmist]

No monetized benefits. It's right there. The word. Read it.

[nailzer]

And new regulations will help businesses move to China or India. The isolated idiots in Washington are to stupid to see what happens in the real world.

[mad libertarian guy]

As a result, EPA anticipates that the proposed EGU New Source GHG Standards will result in negligible CO2 emission changes, energy impacts, benefits or costs for new units constructed by 2020. Likewise, the Agency does not anticipate any notable impacts on the price of electricity or energy supplies...

These proposed EGU New Source GHG Standards is not anticipated to change GHG emissions for newly constructed electric generating units, and is anticipated to impose negligible costs or monetized benefits. EPA typically presents the economic impacts to secondary markets (e.g., changes in industrial markets resulting from changes in electricity prices) and impacts to employment or labor markets associated with proposed rules based on the estimated compliance costs and other energy impacts, which serve as an input to such analyses. However, since the EPA does not forecast a change in behavior relative to the baseline in response to this proposed rule, there are no notable macroeconomic or employment impacts expected as a result of this proposed rule.

But they said that any impact on employment and investment would not be notable. NOT NOTABLE!!

Hey! Regulators who have no idea how business works and have never held a real job in their lives have told us that all will be well because INTENTIONS.

[CatoTheElder]

Let's see if I have this right. EPA coal has to generate 1 MW-h/1000 lb coal.

Coal has a lower heating value of around 12,000 Btu/lb. Roughly 44/12 lbs of CO2 is emitted for every lb of coal burned. So, 3272 Btu of usable heat from coal requires one lb of emissions from coal.

At 100% efficiency in the production of steam and generation of electricity, there are 3412 Btu/kWh.

So, the EPA is being entirely reasonable: they are only requiring that engineers design equipment that is 104% efficient.

Politicians and bureaucrats skirt the law all the time. Certainly engineers can do likewise with the laws of thermodynamics.

[SweatingGin]

Coal has a lower heating value of around 12,000 Btu/lb. Roughly 44/12 lbs of CO2 is emitted for every lb of coal burned. So, 3272 Btu of usable heat from coal requires one lb of emissions from coal.

Tries to focus gin soaked eyes

Could you elaborate/clarify the units in the 44/12 lbs?

I'm not following, but that's awesome if they really did set an impossible standard.

[Stormy Dragon]

It's only an impossible standard if you start from the assumption that all byproducts of combustion MUST be vented to the outside environment.

[SweatingGin]

Doesn't it take energy to sequester carbon?

[CatoTheElder]

It takes lots of energy to sequester. First, air has to be separated for most sequestration schemes. Otherwise, 28% CO2 has to be separated from flue gas, which is no easy task (don't want to try to sequester N2). Air separation requires lots of energy (cryogenic distillation at about -180 degrees C). The CO2 flue gas then has to be cooled to something like ambient temperature; not really so energy intensive but hugely capital intensive and those machines don't build themselves. Next the CO2 has to be liquefied; hugely energy intensive. Then it has to be pipelined to the injection site; it translation of mass requires energy. Then it is injected into geologic formations, which requires more energy. Finally, the sequestration site must be maintained in perpetuity, which theoretically requires infinite energy because forever is a long time.

[CatoTheElder]

One may wonder what air separation has to do with CO2 sequestration.

Conventional coal fired generators use preheated air for combustion air. Since air is only 21% O2 and 79% nitrogen and inerts, flue gas from pure carbon combustion is 21% CO2 [typo above] and 79% nitrogen and inerts. The molecules comprising coal actually have some hydrogen so water vapor is in flue gas as well. Typically coal has some sulfur also, and its combustion products are real pollution if emitted to atmosphere. Combustion reactions also result in the production of NOx. Finally, there are traces of particulate ash in the flue gas. SO2, NOx, and particulates are real pollution, unlike CO2, but modern control technology eliminates well over 95% of the real pollution.

Anyway, for sequestration to work, it would be essential that it process the minimum amount of material. That means getting the N2 and other trace gases out of the combustion air.

Unfortunately, sequestration still doesn't work. As noted above, the industry has gotten really good about eliminating the real pollution associated with coal fired generation. That's why the environmental movement had to create global warming/climate change. It's impossible to eliminate CO2 emissions.

[Greg F]

It's impossible since there is no commercial viable carbon capture and storage technology. Your solution might as well be magic unicorns.

[OldMexican]

Re: Stormy Dragon,

It's only an impossible standard if you start from the assumption that all byproducts of combustion MUST be vented to the outside environment.

Sure, why assume that? It's just the 2nd Law of Thermodynamics, anyway. Psha!

IDIOT!

[CatoTheElder]

Atomic weight of Carbon = 12
Atomic weight of Oxygen = 16

MW of CO2 = 12 + 2*16 = 44

lb CO2 / lb C = 44/12

Sure, coal isn't 100% carbon, but close enough.

[CatoTheElder]

The point is that the EPA has effectively prohibited the construction of coal-fired power plants, and condemned the entire coal industry.

Sequestration is not a viable solution.

This has, of course, been on the agenda for over a decade.

Now, if the anti-fracking crowd can prevail, Obama's work on the economy will be done.

My work here is done.

[Mr Whipple]

That's right - no costs and no benefits. Just new regulations.

Just the simple fact that companies have to consider this regulation creates a cost.

[BiMonSciFiCon]

Lawyers are not cheap.