> September 16, 2008

Air and Radiation Docket and Information Center,

Environmental Protection Agency,

Mailcode: 2822T,

1200 Pennsylvania Ave., NW.,

Washington, DC 20460.

Reference Docket ID No. EPA-HQ-OAR-2008-0318

Comments on, "Advanced Notice of Proposed Rulemaking: Regulating
Greenhouse Gas Emissions under the Clean Air Act"

Imposition by the EPA of carbon taxes or cap & trade regulations will
cause health and safety risks, because proven technologies, or
technologies of sufficient scale, needed to cut CO2 emissions, do not
exist.

The UN has said that developed countries must cut CO2 emissions 80% by
2050 to ensure that worldwide temperatures do not rise dangerously high.
Proposed Senate legislation also calls for an 80% reduction in CO2
emissions.

Though the proposed rule making by the EPA does not establish how much
CO2 emissions should be cut, it is evident that the EPA will adopt large
cuts similar to those proposed by the UN and pending Senate legislation.
The proposed rule making specifically refers to the IPCC in several
locations, and on page 94, said:

> "In 2007, the U.S. and other Parties to the UNFCCC recognized that
> 'deep cuts in global emissions will be required to achieve the
> ultimate objective of the Convention\...' and emphasized '\...the
> urgency to address climate change as indicated...' by the IPCC."

1.  The consequences of implementing carbon taxes or cap & trade
    regulations without proven technologies, or technologies of
    sufficient scale, will have serious health and safety consequences
    for all Americans. These consequences on health and safety are so
    severe that the EPA should not issue carbon taxes or cap & trade
    regulations.

> Each of the consequences cited here are supported by comments in
> sections 2 -- 5.
>
> Serious consequences include:

-   The lack of adequate supplies of electricity will cause blackouts
    placing people in imminent danger through the failure of
    electrically driven equipment, such as elevators, traffic lights,
    street lighting etc.

-   The lack of adequate supplies of electricity will cause blackouts
    causing unemployment as factories close, resulting in the loss of
    medical insurance by workers.

-   The lack of adequate supplies of electricity will cause blackouts
    resulting in loss of air-conditioning which will threaten the health
    of senior citizens, people with existing health conditions and the
    very young. Deaths in Europe during a recent heat wave proved the
    lack of air conditioning is a health threat, especially for senior
    citizens.

-   Blackouts or insufficient supplies of electricity will threaten food
    supplies and the health and safety of people, as refrigeration units
    become inoperative and as food processing equipment is idled by the
    lack of electricity.

-   Inadequate supplies of electricity will result in stores, hospitals
    and other public places having inadequate lighting, (defined by
    light levels in foot candles by the Illuminating Engineering
    Society) that will lead to accidents and expose the public to health
    and safety risks.

-   Inadequate supplies of gasoline will prevent people from accessing
    food stores, drugstores, health providers and similar urgently
    needed sources required for maintaining health and safety.

-   Inadequate supplies of diesel fuel will prevent the delivery of food
    supplies to stores and medical supplies to hospitals, thereby
    endangering the health and safety of people.

-   Inadequate supplies of diesel fuel will prevent the delivery of
    materials and parts to factories, thereby causing factories to close
    with resulting unemployment that will cause employees to lose their
    healthcare insurance.

-   Using inordinate amounts of food stocks, such as corn, soybeans and
    peanuts, for producing Ethanol or Bio-diesel fuels, will deplete the
    supply of food products urgently needed by the public to maintain
    health. These products include cereals, meats, soy products, rice,
    pasta etc.

-   Any need to impose gasoline rationing would have devastating
    consequences on society and on the economy. People would have to be
    limited to 3 gallons of gasoline a week to cut gasoline usage and
    the resulting CO2 emissions by 80%, assuming the average person
    drives 14,000 miles annually. People in rural areas who travel long
    distances to purchase food and medication will be especially hard
    hit by gasoline rationing.

-   Insufficient supplies of electricity and fuels will seriously weaken
    the economy causing unemployment and economic decline. Economic
    decline would eliminate the sources of wealth needed to maintain
    public safety, i.e., policemen and firemen, and maintain national
    defense.

2.  Sources of CO2 Emissions.

> The Energy Information Administration (EIA) has published a report
> showing the sources of CO2 emissions. The report establishes that 39%
> of CO2 emissions in the United States are caused by generating
> electricity and that an additional 20% are the result of using
> gasoline. (Reference: *Emissions of Greenhouse Gases in the United
> States* *2006*, published November 2007 by EIA.)
>
> These two sources of CO2 emissions must be cut significantly if any
> serious effort is made to cut CO2 emissions.
>
> Technologies do not exist that will allow cutting emissions from these
> sources by any significant amount.
>
> Conservation can cut total CO2 emissions by around 5%. (Reference:
> *Carbon Folly*, published by TSAugust in 2008.)

3.  Proposed technologies for cutting CO2 emissions from the generation
    of electricity are examined in this section. This section
    establishes that each of the technologies have either not been
    proven to work or have insufficient scale to have a significant
    impact on cutting CO2 emissions. (Section 4 discusses so called
    "alternative" technologies.)

    a.  Generation of electricity using coal.

> Coal currently generates 50% of the electricity in the United States
> and produces approximately 80% of CO2 emissions from the generation of
> electricity.
>
> The technologies that have been proposed for cutting CO2 emissions
> from the use of coal for generating electricity are:

-   Constructing Integrated Gasification Combined Cycle (IGCC) power
    plants and capturing the CO2 from the syngas produced by the
    process.

-   Capturing CO2 from existing coal fired power plants using amines,
    oxyfuel, chilled ammonia, electro-catalytic oxidation processes.

-   Sequestration of captured CO2 in underground geologic formations.

> (Capturing CO2 must be combined with sequestration in order to cut CO2
> emissions.)

-   Two IGCC plants have been built in the United States, but neither
    was built with the ability to capture CO2.

> The Future Gen project that was intended to demonstrate that carbon
> capture was feasible from an IGCC plant was cancelled by the
> Department of Energy due to the projects high cost.
>
> While carbon capture has been demonstrated on a smaller scale using
> the IGCC process in other countries, the cost of IGCC plants is such
> that there will be great pressure to reduce electric supplies and
> raise electric rates for consumers.
>
> The increased capital cost of IGCC power plants will cause electricity
> rates to be raised by 40% (not counting the cost of sequestration).
> Capital costs of IGCC plants are approximately150% higher than
> conventional coal fired power plants. (Reference: EPA *Final Report,
> Environmental Footprints and Costs of Coal-Based Integrated
> Gasification Combined Cycle and Pulverized Coal Technologies*, July
> 2006)
>
> Both of these estimates do not include the cost of pipelines and
> compressors to transport CO2 to where it can be sequestered. A 30"
> pipeline would cost \$2-4 million per mile.
>
> High rates could cause people to go beyond merely conserving
> electricity and cause them to avoid its use where it is needed to
> maintain personal health and safety, such as avoiding air conditioning
> and safe lighting.

-   Capturing CO2 from existing coal fired power plants has not yet been
    proven feasible, though a few test or prototype installations have
    been, or are being built.

> Tests to date indicate that each of the proposed processes requires
> de-rating the existing power plant by 25% to 40%. This will require
> constructing a new power plant every time three power plants are
> retrofitted with one of these proposed processes. (Reference; (a) *The
> Future of Coal*, by MIT, 2007 and
>
> \(b\) Power magazine, *Carbon Capture Options, parts I and II*, 2008)
>
> Many existing coal fired power plants will not have sufficient space
> to install the equipment required by these proposed carbon capture
> options.
>
> Proposed carbon taxes or cap & trade will require that existing power
> plants that cannot accommodate carbon capture be shut down, thereby
> significantly reducing the amount of electricity available to the
> public and industry.
>
> Whenever it is necessary to replace the electricity lost by shutting
> down existing coal fired power plants or to replace the electricity
> lost when retrofitting existing plants with carbon capture options, it
> will be necessary to build new IGCC plants that have not yet been
> proven viable or by building alternative sources of generating
> electricity (i.e., wind, solar etc.) that do not have sufficient scale
> to replace the needed electricity. (See 4 below)
>
> The added capital costs will result in higher costs for electricity
> that will make (a) many U.S. industries uncompetitive, forcing their
> closure with accompanying unemployment and decrease in national
> wealth, while (b) causing people to avoid using electricity in ways
> that will be detrimental to their safety and health (e.g., avoidance
> of using air conditioning and adequate lighting.)

-   Sequestration has not been proven viable on a sufficiently large
    scale to allow for the capturing and sequestering of large amounts
    of CO2.

> There are a few instances, most notably the Sleipner field in Norway,
> where relatively small amounts of CO2 have been sequestered. The use
> of coal results in around 2,000 million metric tons of CO2 emissions
> annually, while only one million metric tons of CO2 have been
> sequestered annually in the Sleipner field.
>
> It is unknown whether there are sufficient geologic formations in the
> United States to allow sequestering large amounts of CO2.
>
> It is also not known whether CO2 stored in geologic formations will
> leak into the atmosphere or migrate to adjoining geologic formations
> causing contamination of water supplies or aquifers.
>
> Sequestering CO2 from existing coal fired power plants or from new
> plants not built immediately adjacent to a geologic formation, will
> require constructing thousands of miles of pipelines to carry the CO2
> to the location where it would be injected into the ground.
>
> No system has been devised for determining whether CO2 is leaking from
> geologic formations or for otherwise monitoring CO2; including leakage
> from pipelines, most of which will be underground.
>
> Key Senate Bills have not been passed that would address whether there
> are adequate geologic formations for sequestering CO2 or whether these
> formations will prevent CO2 from leaking back into the atmosphere or
> migrate to adjoining geologic formations thereby contaminating them.
> There is a risk that fresh water will be contaminated which will
> threaten the health of people.
>
> Specifially:
>
> S-2144 "\[requires\] the Secretary of Energy to conduct a study of
> feasibility relating to the construction and operation of pipelines
> and carbon dioxide sequestration facilities, and for other purposes."
>
> S-731 Requires the Secretary of the Interior, "To develop a
> methodology for, and complete, a national assessment of geological
> storage capacity for carbon dioxide, and for other purposes."
>
> No action should be taken requiring sequestration until these
> questions have been answered. Taking action now would risk the health
> and safety of Americans. (Refer to item 1.)

a.  Generation of electricity using nuclear power plants, supplies 20%
    of the electricity in the United States while producing zero CO2
    emissions.

    -   It would require building approximately 350 new nuclear power
        plants to eliminate CO2 emissions from coal fired power plants.
        (250 to replace existing coal fired plants and another 100 to
        accommodate growth and the closing of existing nuclear plants
        due to their age and neutron embrittlement.)

> Public resistance to nuclear power precludes building more than a few
> new nuclear plants. In addition, the lack of a trained workforce would
> restrict the number of new nuclear plants that could be built by 2050.
> Building 10 new nuclear plants annually beginning in 2015 is not
> credible and cannot be relied on when establishing public policy.
>
> Carbon taxes and cap & trade should not be implemented if cutting CO2
> emissions relies on the use of nuclear power.

4.  Alternative technologies for generating electricity are examined
    here.

> None of these technologies have, separately or in combination,
> sufficient scale to replace coal fired power generation (a) to
> accommodate population growth or (b) provide the electricity required
> by a healthy economy.

a.  Wind energy:

    -   The capacity factor of wind turbines installed between 2002 and
        2007 has, on average, been below 30%. This is because wind blows
        around 30% of the time at speeds where wind turbines can
        generate electricity.

> The typical wind turbine installed in the United States in the past
> few years is rated 1.5 MW. For example, the order by Pickens for the
> first stage of his large wind farm was for units rated 1.5MW.
>
> After factoring in capacity factor, a 1.5 MW unit will only generate
> 3.9 million kWh/year. This is the same amount of electricity that a
> 0.5 MW nuclear power plant, having a capacity factor of 0.9, would
> produce (recognizing that nuclear plants of this size are not in use).
>
> Based on this direct comparison, it would require 2,000 wind turbines,
> rated 1.5 MW to replace one nuclear power plant. Since the 104 nuclear
> power plants in the United State's provides approximately 20% of the
> nations' electricity, it would require 200,000 wind turbines, rated
> 1.5 MW to generate 20% of the electricity in the United States.
>
> It would require 500,000 wind turbines to replace all the electricity
> generated by coal fired power plants.
>
> The largest number of wind turbines installed in any one year in the
> United States was 1,533 rated, on average, 1.6 MW.
>
> Wind turbine manufacturers are at capacity. For example, General
> Electric has a two year backlog.
>
> Based on these facts and manufacturing capacity constraints, it would
> be impossible for wind turbines to replace a meaningful amount of coal
> fired electricity that is needed to accommodate the growth in
> population or by a healthy economy.
>
> The Energy Information Administration (EIA) forecasts that the United
> States will require an additional 1,046,000 million kWh by2030. This
> is the amount of additional electricity needed annually for a healthy
> economy. (Reference: EIA, *Annual Energy Outlook 2008 with Projections
> to 2030*.)
>
> The U.S. Department of Energy's, National Renewable Energy Laboratory
> (NREL) published a report in May 2008 claiming that 20% of the
> electricity for United States could be supplied by 100,000 wind
> turbines.
>
> Even this lower number of wind turbines will be subject to the same
> manufacturing capacity constraints cited above.
>
> NREL made two unsubstantiated assumptions when arriving at this
> estimate.

-   First, NREL assumed that the capacity factor would increase to 40%.
    NREL based this assumption on taller wind turbines and longer
    blades, neither of which is a valid assumption. Turbine height
    depends on location and longer turbine blades depend on tower
    height. Manufacturing longer blades is yet to been proven viable.
    The NREL report points out these difficulties on Page 42.

-   Second, the report assumes a much higher rating of 2.8 MW for units
    to be installed from now on, which is nearly twice the rating of
    currently produced and installed units. Part of this assumption is
    based on building wind farms in coastal waters, but no wind farm of
    this type has yet to be installed in the United States.

> The report assumes that the technology associated with ocean wind
> turbines can be transferred to land based units. Again, there is no
> factual information to substantiate this claim. The NREL report uses
> terms such as "uncertainty" and "depending on (other assumptions)"
> when describing these assumed claims.
>
> It is extremely unlikely that these "pie in the sky" assumptions will
> be proven correct.
>
> Carbon taxes and cap & trade regulations should not be established
> based on the assumption that wind energy can produce sufficient
> electricity to replace coal fired generation needed to accommodate
> population growth or the growth of a healthy economy.

a.  Solar generated electricity.

-   Concentrating solar has made important improvements, but is only
    viable in the Southwestern part of the United States. (Reference:
    *Carbon Folly*, published by TSAugust in 2008.)

> Proposals have been made to transport this electricity from the
> Southwest across America using HVDC transmission. (Reference:
> Scientific American magazine, January 2008.)
>
> The largest DC transmission line in the world is the Itaipu project in
> Brazil. The Itaipu line is 988 miles long, which is substantially
> shorter than distances from the Southwest to Eastern areas of the
> United States. Rights of way for the required large number of HVDC
> lines are not available. (Reference: *Carbon Folly*, published by
> TSAugust in 2008.)
>
> Solar cannot generate electricity when the sun doesn't shine. There is
> no currently available technology for storing large amounts of
> electricity generated while the sun shines. Solar is, in essence, an
> intermittent source that cannot be relied on for critical
> applications.
>
> Roof mounted photovoltaic panels are very costly; and, like all solar
> power, they only work when the sun shines. This makes their use
> ineffective in Northern areas of the United States.
>
> Solar lacks the scale need to replace large amounts of electricity.
> Solar currently provides 0.01% of the nation's electricity. (Source:
> EIA.)
>
> Carbon taxes and cap & trade regulations should not be established
> based on the assumption that solar energy can produce sufficient
> electricity to replace coal fired generation needed to accommodate
> population growth or growth of a healthy economy.

a.  Other alternative sources of electricity.

    -   Geothermal, hot rocks, wave power and river power all lack the
        scale to produce sufficient electricity to support the
        imposition of carbon taxes or cap & trade regulations.

> Of these more esoteric sources of electricity, only geothermal has
> been proven to work where there are sources of hot steam or water
> emanating from underground magma formations.
>
> There are a few such locations in the western United States, but they
> can only provide a small amount of electricity or approximately 22,000
> MW, or 2% of current U.S. electricity generating capacity. (Reference:
> Environmental and Energy Study Institute (EESI) 2006, *Geothermal
> Energy: Tapping the Energy in the Earth's Core*.)
>
> Heat pumps can help conserve electricity and would be included as part
> of the reductions in CO2 emissions resulting from conservation.
>
> Carbon taxes and cap & trade regulations should not be established
> based on the assumption that geothermal energy can produce sufficient
> electricity to replace coal fired generation needed to accommodate
> population growth or the growth of a healthy economy.

5.  Alternatives for cutting CO2 emissions from gasoline are examined
    here.

> There are no substitutes for gasoline or diesel fuel that can replace
> a significant amount of these fuels. Without gasoline and diesel fuel
> the economy would come to a standstill and create widespread health
> and safety risks.
>
> The only possibilities for significantly cutting CO2 emissions from
> gasoline and diesel fuel are to (1) replace the internal combustion
> engine with fuel cells or (2) develop a vehicle that runs largely on
> battery power.
>
> Biofuels can replace only a fraction of the oil used for gasoline and
> diesel fuel. There is also evidence that biofuels will not reduce CO2
> emissions due to the energy needed to produce these alternative fuels
> and the CO2 produced while producing ethanol. This issue should be
> resolved before establishing carbon taxes or cap & trade regulations.

a.  Biofuels have been proposed as a substitute for gasoline and diesel
    oil.

-   Domestic sources of biofuels are corn for ethanol and soybeans,
    peanuts and waste grease for diesel fuel.

> The maximum amount of ethanol that can be produced from corn, assuming
> that 1/3 of the corn crop is used for that purpose, equals 0.8 million
> barrels per day (mb/d) of oil. This is less than 10% of the gasoline
> used in the United States.
>
> Cellulosic ethanol has been proposed as a possible source of ethanol
> and diesel fuel. Cellulosic fuels are still experimental.
>
> If cellulosic fuels become viable sometime in the future, it will only
> be possible to produce a quantity of cellulosic ethanol equal to 2.0
> mb/d of gasoline (0.8 mb/d from corn ethanol and 1.2 mb/d from
> cellulosic ethanol).
>
> Replacing 2.0 million barrels of oil daily would only cut projected
> gasoline usage in 2050 by 18%. This assumes using all available corn
> stover and growing cellulosic plants (switch grass etc.) on all 30
> million acres of unused farm land. (References: (a) Discover Magazine,
> August 2006 (b) "*A Strategy for Achieving Independence from Foreign
> Oil*", TSAugust 2005 revised 2007 (c) *Biofuels, Food or Wildlife*, by
> Dennis Avery, September 2006)
>
> Using corn, soy beans, peanuts and other food crops endangers the
> health of people who will not be able to afford the food for a
> balanced diet.
>
> Safety will be compromised as evidenced by the riots in several
> countries because of high food prices attributable to the use of food
> crops for ethanol.
>
> The use of waste grease has been suggested as a source of bio-diesel
> fuel. The U.S. generates 2-3 billion gallons of waste grease annually,
> but this would only produce 0.1 mb/d of biodiesel. (Source: EPA.)
>
> Carbon taxes and cap & trade regulations should not be established
> based on the assumption that biofuels can replace more than a fraction
> of the gasoline and diesel fuels needed to accommodate population
> growth or growth of a healthy economy.
>
> Because ethanol cannot be produced in sufficient quantities to
> significantly cut CO2 emissions, it will be necessary to impose
> gasoline rationing if carbon taxes and cap & trade regulations are
> established that require substantial cuts in CO2 emissions from the
> use of gasoline. Gasoline rationing will be detrimental to the health
> and safety of people. (See 1 above.)

b.  Plug-in Electric Vehicles (PHEV's) have been proposed as a
    replacement for gasoline powered automobiles. They will not be
    suitable for replacing over-the-road highway trucks that use at
    least 2 million barrels of diesel fuel daily.

    -   PHEV's hold great promise but will require large batteries to
        power them electrically for at least 40 miles before having to
        use gasoline. CalCars has estimated that PHEV's can achieve over
        100 mpg.

> Lithium-ion batteries are currently proposed for use in PHEV's, but
> there is no assurance that they will be successful or that there will
> be a sufficient supply of raw materials to produce the large numbers
> of batteries needed for these vehicles.
>
> In addition, it will take 50 years for PHEV's to replace 75% of the
> automobiles used in the United States. This is the level of
> penetration required for PHEV's to cut gasoline usage by approximately
> 65% from projected levels of gasoline usage. Achieving this level of
> penetration earlier, will require scrapping vehicles before the end of
> their useful economic life, since the average life of a car is around
> 14 years. (Reference computer projections developed by TSAugust, and
> published in part in *A Strategy for Achieving Independence from
> Foreign Oil*.)
>
> It should be noted that the electricity used for recharging batteries
> must come from a source of sufficient scale that doesn't emit CO2, in
> order for these reductions in CO2 to be achieved by PHEV's.
>
> Carbon taxes and cap & trade should not be implemented for cutting CO2
> emissions from gasoline, since PHEV's will have little ability to cut
> CO2 emissions from gasoline for several decades and may never prove to
> be viable in the quantities needed. There is no comparable technology
> available for highway trucks using diesel fuel.
>
> There is no guarantee that PHEV's will be successful or able to
> account for 75% of U.S. passenger vehicles, in which case it will be
> necessary to impose gasoline rationing if carbon taxes and cap & trade
> regulations are established that require substantial cuts in CO2
> emissions from gasoline or diesel fuel. (See item 1, for the
> consequences of gasoline rationing.)

c.  Hydrogen powered vehicles using fuel cells.

-   Fuel cells are experimental and cost several times as much as
    internal combustion engines.

> Until reasonable methods for storing hydrogen on vehicles are
> developed, it is unlikely that vehicles will be produced in quantity,
> using 10,000 psi cylinders or cryogenic cylinders (thermos bottles)
> for storing hydrogen on a vehicle.
>
> Metal hydrides and other substances have not yet been able to store
> and release hydrogen as needed.
>
> Producing hydrogen by electrolysis requires a source of electricity
> that does not release CO2 emissions. Electrolysis for producing
> hydrogen would require huge increases in generating capacity. This
> compounds the problems described earlier in item 3.
>
> High temperature nuclear reactors could produce hydrogen centrally as
> could steam methane reduction.
>
> Centrally produced hydrogen has to be transported using cryogenic
> trucks (powered by diesel fuel) or by specially built pipelines.
> Refrigerating hydrogen to -423 degrees F. uses the equivalent of
> approximately 25% of hydrogen's energy content. (References: (a)
> *Hydrogen Today*, published by TSAugust 2004 and (2) *Hydrogen Reality
> and Policy*, published by TSAugust 2004.)
>
> For these reasons, it is very unlikely that Hydrogen powered vehicles
> will be produced in sufficient quantities to cut CO2 emissions.
>
> Carbon taxes and cap & trade should not be implemented if hydrogen
> powered vehicles are needed for cutting CO2 emissions.

Summary:

The consequences cited in item 1 will be exacerbated by the growth in
U.S. population of approximately139 million people between 2000 and
2050. (Source: U.S. census projections.) Carbon taxes and cap & trade
regulations should not be implemented unless the consequences of
population growth have been analyzed and thoroughly understood.

All references are incorporated as an integral part of these comments.

> Donn Dears
>
> President TSAugust

Note: Mr. Dears, a General Electric Company, Senior Executive (Retired),
has extensive experience in power generation, transmission, distribution
and energy issues.

Copy To:

Office of Information and Regulatory Affairs,

Office of Management and Budget (OMB),

Attn: Desk Officer for EPA,

725 17th St. NW., Washington, DC 20503.