In its recent report on climate change, the Government Accounting Office (GAO) recommended that the President establish an interagency task force to examine issues currently impeding large-scale commercial deployment of carbon capture and storage (CCS) and to develop a strategy for federal agencies to address those issues. The GAO also recommended that the Secretary of Energy continue to put money into supporting technologies that can reduce greenhouse gas (GHG) emissions at existing coal-fired power plants. Finally, the GAO recommended that the Administrator of the U.S. EPA examine barriers to CCS development under RCRA, CERCLA, and the Clean Air Act in addition to its current rulemaking efforts under the Safe Drinking Water Act.
The GAO report, Federal Actions Will Greatly Affect the Viability of Carbon Capture and Storage as a Key Mitigation Option (GAO-08-1080), addresses carbon capture and storage, which is seen as an essential technology for addressing greenhouse gas emissions because it has the potential to greatly reduce CO2 emissions from power plants while allowing for projected future increases in electricity demand. CCS is a process of separating CO2 from other gases produced in fuel combustion and other industrial processes, transporting the CO2 via pipeline to an underground storage location, and injecting and storing it long-term in underground geologic formations.
The GAO’s recommendations were made in response to the three primary barriers that it identified as currently restricting CCS deployment, which included (1) underdeveloped and costly CO2 capture technology, particularly from existing coal-fired power plants, which according to the GAO are the single largest source of CO2 emissions in the United States; (2) regulatory and legal uncertainties over CO2 capture, injection, and storage including uncertainty regarding liability for CO2 leakage and ownership of CO2 once injected; and (3) absence of a national strategy to control CO2 emissions (such as an emissions trading plan, emissions tax, or other mandatory control of CO2 emissions), without which the GAO concludes the electric utility industry has little incentive to capture and store its CO2 emissions and federal agencies are deterred from addressing other important practical issues, such as resolving how stored CO2 would be treated in a future CO2 emissions trading plan.
Both the Department of Energy (DOE) and the U.S. Environmental Protection Agency (USEPA) responded to the report. The DOE recognized that the GAO’s report subtly criticized the DOE’s heavy focus on integrated gasification combined cycle (IFCC) technology applicable at new coal fired power plants versus more limited funding of research and development applicable to existing pulverized coal power plants. The DOE responded that the “goal is to drive CCS cost sufficiently low to encourage large developing countries such as China and India to eventually deploy CCS as they continue to build their economic expansion on their large, domestic coal resource bases.” The DOE went on to state that “if these countries do not adopt CCS in a timely manner, it may not be possible to reduce greenhouse gas emissions sufficiently to limit atmospheric concentrations of GHGs to acceptable levels.”
The DOE responded to the GAO’s recommendation for an interagency task force by pointing out that the DOE-led interagency Climate Change Technology Program (CCTP) already exists, as authorized by the Energy Policy Act of 2005, and includes representation from relevant federal agencies. The GAO’s final report notes that the CCTP focuses on technology, and does not address legal and institutional issues identified by the GAO such as CO2 pipeline regulation and infrastructure or liability for stored CO2, among others issues.
The USEPA responded to the GAO’s recommendations by stating that “there is no regulatory impediment to seeking a permit for large-volume injection of CO2 under the existing Underground Injection Control (UIC) program pursuant to the Safe Drinking Water Act.” The USEPA further clarified that as with existing UIC wells, the owner/operator of a ‘geologic sequestration site’ will be held liable indefinitely for potential damages caused by leakage of CO2.