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27–318 PDF 2017

S. HRG. 115–104 

EXPANDING AND ACCELERATING THE 

DEPLOYMENT AND USE OF CARBON CAPTURE, 

UTILIZATION, AND SEQUESTRATION 

HEARING 

BEFORE THE

COMMITTEE ON 

ENVIRONMENT AND PUBLIC WORKS 

UNITED STATES SENATE 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

SEPTEMBER 13, 2017 

Printed for the use of the Committee on Environment and Public Works 

( 

Available via the World Wide Web: http://www.fdsys.gov 

(II) 

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

JOHN BARRASSO, Wyoming, Chairman 

JAMES M. INHOFE, Oklahoma 

SHELLEY MOORE CAPITO, West Virginia 

JOHN BOOZMAN, Arkansas 

ROGER WICKER, Mississippi 

DEB FISCHER, Nebraska 

JERRY MORAN, Kansas 

MIKE ROUNDS, South Dakota 

JONI ERNST, Iowa 

DAN SULLIVAN, Alaska 

RICHARD SHELBY, Alabama 

THOMAS R. CARPER, Delaware 

BENJAMIN L. CARDIN, Maryland 

BERNARD SANDERS, Vermont 

SHELDON WHITEHOUSE, Rhode Island 

JEFF MERKLEY, Oregon 

KIRSTEN GILLIBRAND, New York 

CORY A. BOOKER, New Jersey 

EDWARD J. MARKEY, Massachusetts 

TAMMY DUCKWORTH, Illinois 

KAMALA HARRIS, California 

RICHARD M. RUSSELL, Majority Staff Director 

GABRIELLE BATKIN, Minority Staff Director 

(III) 

C O N T E N T S 

Page 

SEPTEMBER 13, 2017 

OPENING STATEMENTS 

Barrasso, Hon. John, U.S. Senator from the State of Wyoming .......................... 1 

Carper, Hon. Thomas R., U.S. Senator from the State of Delaware ................... 2 

WITNESSES 

Fry, Matt, Policy Advisor, Office of Governor Matt Mead ................................... 11 

Prepared statement .......................................................................................... 14 

Responses to additional questions from: 

Senator Barrasso ....................................................................................... 24 

Senator Sullivan ........................................................................................ 26 

Senator Whitehouse .................................................................................. 27 

David Greeson, Vice President of Development, Nrg Energy .............................. 28 

Prepared statement .......................................................................................... 30 

Responses to additional questions from: 

Senator Barrasso ....................................................................................... 39 

Senator Sullivan ........................................................................................ 42 

Senator Whitehouse .................................................................................. 42 

Friedmann, S. Julio, CEO, Carbon Wrangler Llc ................................................. 44 

Prepared statement .......................................................................................... 46 

Responses to additional questions from: 

Senator Barrasso ....................................................................................... 52 

Senator Whitehouse .................................................................................. 54 

ADDITIONAL MATERIAL 

Statements: 

Bluegreen Alliance ........................................................................................... 92 

Clean Air Task Force ....................................................................................... 107 

Department of Energy, Staff Report to the Secretary on Electricity Markets and Reliability ....................................................................................... 113 

National Coal Council ...................................................................................... 121 

Article; The Weekly Standard: Revolution? ........................................................... 184 

(1) 

EXPANDING AND ACCELERATING THE DEPLOYMENT AND USE OF CARBON CAPTURE, 

UTILIZATION, AND SEQUESTRATION 

WEDNESDAY, SEPTEMBER 13, 2017 

U.S. SENATE, 

COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS, 

Washington, DC. 

The committee met, pursuant to notice, at 10:04 a.m. in room 

406, Dirksen Senate Office Building, Hon. John Barrasso (chairman of the committee) presiding. 

Present: Senators Barrasso, Carper, Inhofe, Capito, Boozman, 

Fischer, Rounds, Ernst, Sullivan, Whitehouse, Merkley, Gillibrand, 

Booker, Markey, Duckworth, and Harris. 

OPENING STATEMENT OF HON. JOHN BARRASSO, 

U.S. SENATOR FROM THE STATE OF WYOMING 

Senator BARRASSO. Good morning. I call this hearing to order. 

Today we are here to discuss promising technologies that both 

advance environmental aims and support continued use of our 

abundant energy resources. Those technologies are known as carbon capture, utilization, and sequestration, or CCUS. 

In Wyoming we have tremendous coal, natural gas, and oil resources. These resources fuel our State’s economy. CCUS presents 

a win-win opportunity. Here is the concept. Instead of releasing the 

carbon dioxide into the atmosphere when we combust fossil fuels, 

CCUS allows us to turn the carbon dioxide into a useful commodity. Through this technology, carbon dioxide is captured, where 

the fuel is burned, such as a power plant, and then transported, 

used, and ultimately stored. 

One key use for this carbon captured dioxide is enhanced oil recovery. Enhanced oil recovery operations, also known as EOR, are 

operations that use carbon dioxide, and they have been around for 

more than 40 years in the United States. CO2 is injected into wells 

that otherwise economically couldn’t produce oil. By capturing the 

carbon dioxide, we have an opportunity to increase the supply of 

carbon dioxide available for enhanced oil recovery and produce oil 

that otherwise could not have been harvested. 

The colored map on this area show all of the oil basins where 

carbon dioxide-enabled enhanced oil recovery could be further used. 

As you can see, there are areas all over the United States. 

CCUS and enhanced oil recovery should play an important role 

in a truly all-of-the-above energy policy. With CO2 enabled oil recovery, we do have a win-win situation; we have the potential to 

2 

make it economical, to extract more than 60 billion barrels of oil 

in this Country. And in producing the oil, billions of tons of carbon 

dioxide would then be stored, which would lead to a significant decrease in carbon dioxide emissions into the atmosphere. 

The International Energy Agency estimates that the technology 

could enable the storage of 140 billion tons of carbon dioxide in oil 

reservoirs all around the world. The Clean Air Task Force recently 

reported that using carbon dioxide captured through CCUS ‘‘can result in a 63 percent net reduction in carbon dioxide emissions for 

every barrel of oil produced.’’ This is an impressive number and one 

that should grab all of our members’ attention. 

America is currently a leader in CCUS technology, and we want 

to keep it that way. Use of fossil fuels globally is projected to increase over time. The U.S. Energy Information Administration predicts global increases in coal use through 2040. Encouraging American innovation is the right approach to continuing American leadership, leadership in the development of technologies to lower the 

emissions associated with fossil fuel use. Through American leadership we create opportunities to export our innovations around the 

world. 

My colleagues on both sides of the aisle recognize the critical role 

that CCUS can play in our future. This Congress, Senator Capito, 

Senator Whitehouse, and I were original cosponsors of bipartisan 

legislation introduced by Senator Heitkamp known as the FUTURE Act, or the Furthering carbon capture, Utilization, Technology, Underground storage, and Reduced Emissions Act. The FUTURE Act extends and expands tax credits for facilities with CCUS 

technologies, and I am proud to say the bill now has over 24 bipartisan cosponsors. 

This Committee has an opportunity to complement the FUTURE 

Act through our efforts by reviewing statutes and regulations that 

impact carbon capture, utilization, and storage. Now is the time to 

see what more we could do to encourage and remove impediments 

to the use and deployment of CCUS. We need to make sure our 

laws and regulations accelerate, not hinder, our environmental 

goals. 

I look forward to working with members of the Committee in a 

bipartisan way to examine how we can expand and accelerate 

CCUS deployment and use. When we do that, we promote American leadership in technology innovation, increase our energy security, and improve our environment. 

I would now like to invite the Ranking Member for his testimony. 

OPENING STATEMENT OF HON. THOMAS R. CARPER, 

U.S. SENATOR FROM THE STATE OF DELAWARE 

Senator CARPER. Thanks, Mr. Chairman. 

You know, we never say, I want to work in a partisan way; we 

always say we want to work in a bipartisan way. We oftentimes 

work in a partisan way, but we always say we want to work in a 

bipartisan way, and this is one where we can work in a bipartisan 

way. 

Ironically, one of the first people I ever talked with about clean 

coal technology was Robert Byrd, who was from my native State 

of West Virginia for many years. He was not born there, but cerVerDate Aug 31 2005 13:29 Nov 07, 2017 Jkt 000000 PO 00000 Frm 00006 Fmt 6633 Sfmt 6633 S:\_EPW\DOCS\27318.TXT VERN
3 

tainly grew up there and served them forever. I had breakfast this 

morning with Ann Barth, who for many years was a State director. 

One of the things we talked about was the efforts going on in West 

Virginia to try to diversify the economy and she gave me encouraging reports. So this is rather timely, and I am channeling Robert 

Byrd this morning as we convene, Mr. Chairman, for this hearing. 

I want to say to our witnesses, good to see you all. We welcome 

you to this important hearing and we welcome your efforts to help 

enable us to work in a bipartisan way. 

It is refreshing to have a hearing that looks at solutions to climate change, as opposed to a hearing that fuels the debate over the 

science of climate change. And I believe one of the most important 

roles for our Government, and my colleagues have heard me say 

this more than a few times, is not to create jobs, but to create a 

nurturing environment for job creation. 

Another critical role is to help protect public health and try to 

ensure that all Americans can pursue life, liberty, and happiness; 

and luckily the two are not mutually exclusive. 

I spent the early years of my life growing up in communities in 

West Virginia whose economies depended largely on coal, and for 

a short time I was the son of a coal miner. Many years later I am 

now a U.S. Senator who is privileged to represent the lowest lying 

State in our Nation, that is Delaware. But I haven’t entirely forgotten my roots. 

I have long believed that the deployment of technologies that 

allow us to burn coal and electric power generation in a much 

cleaner way, with significant reduction in emissions, can be a real 

win-win for coal communities, for manufacturing, and for our climate. 

Today our Country is in the midst of a clean energy revolution, 

as we know. Didn’t happen by accident. Over the last 8 years, 

starting with the Recovery Act, the Federal Government has provided economic incentives and environmental targets to encourage 

investments in clean energy. 

As a result, $507 billion have been invested in the clean energy 

sector over the past 10 years and our Country is a leader today in 

exporting clean air and clean energy technology. Thanks in part to 

these investments in clean energy and energy efficiency, American 

consumers are paying less for energy today and jobs are being created here at home to produce these clean energy technologies. 

Following 8 years of smart economic and environmental policies, 

America has largely rebounded from one of the greatest economic 

downturns in our history, the Great Recession. Until last week, we 

have enjoyed lower energy costs at the meter and the pump for 

consumers, and we implemented clean air protections that protect 

public health and our climate, while adding some 16 million jobs 

over the past 6 years. Not too shabby when compared to the 6- 

years that preceded it. 

However, as we know, not all of our communities have felt the 

benefits of the clean energy economic boom. Too many of our manufacturing plants remain dormant in States across the Country, and 

a number of them can be found in my State of West Virginia and 

my current home State of Delaware, and the States of all of us, I 

suspect, all around this table. In addition, many of our coal mines 

4 

and coal-fired utilities are continuing the decades long trend of 

closing or reducing production. 

Investments in carbon capture and storage can help slow or reverse this trend. These investments can lead to good paying American jobs in engineering and design, as well as manufacturing, installing and operating technology that is made in America and sold 

all over the world. Investments in this technology are also critical 

if we are going to meet our long-term climate goals. 

But just as with other coal-related technologies, the barriers to 

carbon capture and storage are largely financial, not environmental. Investors have shied away from expensive large-scale carbon capture projects in part because energy prices are low, and this 

Country has struggled to put a price on carbon usage. The reluctance of investors to invest is not because we require that sequestered carbon stays sequestered, or that these operations meet other 

basic and important environmental requirements. 

Walking away from climate and clean air protections has only 

compounded the problem. As a result, we are well on the way of 

ceding the economic opportunities of carbon capture technology to 

other countries, such as China, which only hurts the very communities that our President and I think all of us want most to help. 

So, in closing, let me reiterate that we don’t need to scrap our 

environmental standards to provide a nurturing environment for 

American innovation and economic investment in carbon sequestration technologies. They are not mutually exclusive. 

With that, we welcome our witnesses. We look forward to hearing from you and having a robust conversation. Thank you all. 

[The prepared statement of Senator Carper follows:] 

5 


27318.001

Opening Statement of Senator Tom Carper 

EPW Full Committee Oversight Hearing on "Expanding and Accelerating the 

Deployment and Use of Carbon Capture, Utilization, and Sequestration" 

September 13, 2017 

Mr. Chairman, thank you for convening this hearing today, and 

thank you to our witnesses for joining us. 

It is refreshing to have a hearing that looks at solutions to climate 

change, as opposed to a hearing that fuels the debate over the 

science of climate change. 

I believe one of the most important roles for government is to create 

a nurturing environment for job creation and job 

preservation. Another critical role is to help protect public health 

and try to ensure that all Americans can pursue life, liberty and 

happiness. Luckily, these two are not mutually exclusive. 
6 


27318.002

I spent the early years of my life growing up in communities in West 

Virginia whose economies depended largely on coal. For a short 

time, I was the son of a coal miner. Many years later, I am now a 

U.S. Senator who is privileged to represent the lowest-lying state in 

our nation; however, I haven't entirely forgotten my roots. 

I have long believed that the deployment of technologies that allow 

us to burn coal in electric power generation in a much cleaner way 

with significant reductions in emissions can be a real win-win for 

coal communities, for manufacturing and for our climate. 

Today, our country is in the midst of a clean energy revolution, and 

that didn't happen by accident. Over the last eight years, starting 

with the Recovery Act, the federal government has provided 

economic incentives and environmental targets to encourage 

investments in clean energy. 
7 


27318.003

As a result, $507 billion dollars have been invested in the clean 

energy sector over the past ten years, and our country is a leader in 

exporting clean air and clean energy technology. 

Thanks in part to these investments in clean energy and energy 

efficiency, American consumers are paying less for energy today, 

and jobs are being created here at home to produce these clean 

energy technologies. 

Following eight years of smart economic and environmental policies, 

America has largely rebounded from one of the greatest economic 

downturns in our history. Until last week, we've enjoyed lowered 

energy costs at the meter and the pump for consumers, and we've 

implemented clean air protections that protect public health and our 

climate, all while adding 16 million jobs over the past six years. Not 

too shabby when compared to the six years that preceded it. 
8 


27318.004

However, as we know, not all of our communities have felt the 

benefits of this clean-energy economic boom. Too many of our 

manufacturing plants remain dormant. In fact, a number of them 

can be found in my home state of Delaware, as well as in the states 

of many of us who are members of this committee. In addition, 

many of our coal mines and coal-fired utility plants are continuing 

the decades-long trend of closing or reducing production. 

Investments in carbon capture and storage can help slow or reverse 

this trend. These investments can lead to good paying American 

jobs in engineering and design, as well as in manufacturing, 

installing and operating technology that is made in America and 

sold all over the world. Investments in this technology are also 

critical if we are going to meet our long-term climate goals. 
9 


27318.005

But, just as with other coal-related technologies, the barriers to 

carbon capture and storage are largely financial-not 

environmental. 

Investors have shied away from expensive, large-scale carbon 

capture projects, in part, because energy prices are low, and this 

country has struggled to put a price on carbon usage. The 

reluctance of investors to invest is not because we require that 

sequestered carbon stay sequestered or that these operations meet 

other basic and important environmental requirements. 

Walking away from climate and clean air protections has only 

compounded the problem. As a result, we are well on the way to 

ceding the economic opportunities of carbon capture technology to 

other countries, such as China, which only hurts the very 

communities that our President says he wants to help the most. 
10 


27318.006

In closing, let me reiterate that we don't need to scrap our 

environmental standards to provide a nurturing environment for 

American innovation and economic investment in carbon 

sequestration technologies. They are not mutually exclusive. 

With that said, I look forward to hearing from our witnesses on how 

we might be able to work together to create a win-win situation. 

America could us a few of those right now! 
11 

Senator BARRASSO. Thank you very much, Senator Carper. 

We have, to testify today, Dr. Julio Friedmann, who is the Distinguished Associate of the Energy Futures Initiative; Mr. David 

Greeson, who is the Vice President of Development for NRG Energy; and, in addition, we have Mr. Matt Fry, who is the Policy Advisor of the Office of the Wyoming Governor, Matt Mead. 

Before turning to you, Mr. Fry, I just want to point out that Mr. 

Fry has a distinguished career in the natural resource field, spanning approximately 20 years, including time in the private and 

public sectors. He served as a staff biologist at the Wyoming Game 

and Fish Department before assuming his current role in Governor 

Mead’s office as a policy advisor. 

Mr. Fry has a Bachelor of Science degree in biology, with a minor 

in chemistry, and a Masters in Natural Resource Law from the 

University of Denver in the Sturm School of Law. 

While he is a native of Virginia, we are glad he has chosen to 

make Cheyenne his home. His work in Governor Mead’s office includes management of the Wyoming Pipeline Corridor Initiative. 

The Initiative is a first of its kind endeavor by a State to encourage 

and facilitate the development of a CO2 pipeline corridor. 

I commend Mr. Fry for his leadership on this Initiative and look 

forward to his testimony. 

I remind all of the witnesses that your full written testimony will 

be made part of the official hearing record, so please try to keep 

your statements to 5 minutes; that way we might have time for 

questions. We look forward to hearing your testimony. 

Mr. FRY. 

STATEMENT OF MATT FRY, POLICY ADVISOR, OFFICE OF 

GOVERNOR MATT MEAD 

Mr. FRY. Good morning, Mr. Chairman, members of the Committee. Appreciate the opportunity to talk with you all this morning about CCUS. 

Mr. Chairman, as you are well aware, Wyoming is heavily dependent upon the development of fossil fuels. Coal, oil, natural gas 

are responsible for approximately 65 percent of our State’s revenue. 

A number of factors in recent years have led to the decline in these 

industries. As a result, State coffers have shrunk and our citizens 

find it more and more difficult to obtain stable, profitable employment. In order to address these issues, Governor Mead has spearheaded a number of initiatives, with carbon capture, utilization, 

and storage, or CCUS, playing a major role. 

The deployment of CCUS technology is of great importance not 

only to Wyoming, but to the Nation as a whole. CCUS provides us 

with the opportunity to treat CO2 as a valuable commodity, rather 

than an end-product with no value. However, there are substantial 

challenges associated with its implementation. We recognize these 

challenges and are working diligently to manage them head-on. 

Development of infrastructure requires myriad regulatory review 

processes and approvals. The most costly and time-consuming of 

these regulatory processes is the one dictated by the National Environmental Policy Act, or NEPA. NEPA analyses historically were 

completed in relatively short timeframes and at acceptable costs. 

Unfortunately, in recent years they have evolved in such a way 

12 

that they may now take upwards of a decade and tens of millions 

of dollars to complete. From a project proponent’s perspective, this 

drawn out process creates a number of problems, which I have illustrated in my written testimony. 

So I am not here this morning to suggest that NEPA be abolished or even significantly amended. NEPA is meant to function 

merely as a procedural law, which requires that impacts of a proposed action and alternative actions be disclosed for the purposes 

of informing a decision. The fundamental basis of the law has eroded, which has led NEPA to be utilized in a prescriptive manner, 

and to a large extent it has become a tool to either defend or inform litigation. I suggest we take a step back and return the process to its original intent. 

While this recommendation sounds simplistic, the reality is that 

it will require a significant paradigm shift, as well as cultural 

changes. Reversing the inertia of NEPA’s current course will require significant leadership, and I submit that this Committee is 

eminently qualified to undertake and accomplish this goal. 

Additionally, I suggest a foundational change to the NEPA process. NEPA requires a specific sequence of actions to reach a final 

decision. It has been my experience that far too many resources are 

devoted to these formal steps and not nearly enough work is done 

on the front end of these projects in order to build a strong base. 

There are a number of agency activities that occur behind the 

scenes to prepare for the NEPA process. Unfortunately, Federal 

agencies don’t effectively reach out to other entities that are oftentimes much more knowledgeable and may have far greater insight 

into potential constraints that inevitably lead to delays. Adding 

this outreach on the front end will undoubtedly reduce time and resources required to reach a decision. 

In Wyoming, we are actively developing a project that exemplifies this effort to build a strong foundation in order to minimize future analysis requirements. We call it the Wyoming Pipeline Corridor Initiative, or WPCI. WPCI is a sound strategy to streamline 

the NEPA process for pipeline infrastructure without compromising 

the integrity of the Act or its processes. While developing this 

project proposal, we coordinated with industry, local State and Federal agencies, non-governmental organizations, individuals that 

have intimate knowledge of the lands within our borders, and other 

authorities with experience in the CO2 -EOR industry. 

One of the primary purposes of the pipeline network is to connect 

oil fields suitable for EOR with CO2 sources. Once we complete our 

EAS and authorization is approved, companies will be able to build 

their infrastructure within the corridors and reduce time and reduce costs, as will have already dedicated State resources to completing the bulk of the NEPA analysis. 

I provided a third description of the WPCI and all of its benefits 

in my written testimony, but to highlight just a few: WPCI will 

spur the development of up to 1.8 billion barrels of oil, while potentially storing 20 trillion cubic feet of CO2 ; WPCI will provide a 

large number of jobs for those building, maintaining, and operating 

pipelines and EOR fields; and WPCI provides a balanced approach 

of natural resource utilization and environmental conservation. 

13 

We currently are anxiously awaiting the approval from BLM to 

begin our NEPA process and, once finalized, WPCI can serve as a 

model that could be followed by any States interested in streamlining the NEPA work. 

Once again, I appreciate the opportunity to present this testimony today, and I would be happy to answer any questions. Thank 

you. 

[The prepared statement of Mr. Fry follows:] 

14 


27318.007

Testimony of Matt Fry 

Policy Advisor to Wyoming Governor Matt Mead 

Before the U.S. Senate Committee on Environment and Public Works 

September 13, 2017 

Mr. Chairman and Members of the Committee, 

I appreciate the opportunity to testify before the Committee today. My name is Matt Fry and I 

serve as a Natural Resource Policy Advisor to Wyoming Governor Matt Mead. I have worked in 

the natural resource management and planning fields, both public and private sectors, for 

approximately 20 years. I look forward to relating the challenges and opportunities associated 

with regulatory processes required for carbon capture, utilization and storage (CCUS) 

deployment, and specifically carbon dioxide (C02) transport and the necessary development of 

pipeline infrastructure. 

Wyoming is heavily dependent upon the development of fossil fuels. Coal, oil, and natural gas 

are responsible for approximately 65% of our state's revenue. A number of factors in recent 

years have led to the decline of these industries. As a result, state coffers have shrunk and our 

citizens find it more and more difficult to obtain stable, profitable employment. While we are 

not here to debate the merits of climate change, the reality is that regulations to reduce climate 

impacts have had an effect on Wyoming. In order to address this issue, while preserving our 

economy, Governor Mead has spearheaded a number of initiatives, with CCUS playing a major 

role. 

The deployment of CCUS technology is of great importance not only to Wyoming, but to the 

nation as a whole. CCUS provides us with the opportunity to treat C02 as a valuable 

commodity, rather than an end product with no value. However, there are substantial challenges 

associated with its implementation. These include rigorous and costly regulatory processes, lack 

of federal and state policies that incentivize CCUS, minimal financial certainty for prospective 

project developers, and a number of other factors that we may not have time to discuss today. 

Under the leadership of Governor Mead, we recognize these challenges, and are working 

diligently to address them head-on. The State of Wyoming does not have all of the answers, but 

based on our work, I do believe we can present several opportunities to reduce regulatory 

challenges. 

Regulatory Challenges 

Development of infrastructure projects requires myriad regulatory review processes and 

approvals. A typical pipeline project in a single western state, with mixed federal, state, and 

privately owned lands may require upwards of30 reviews, permits, and approvals from federal, 

state, and local authorities. If a proposed project were to cross multiple states, this number 

would increase accordingly. While the combination of these regulatory reviews is onerous, they 

are all required by various laws and regulations. 
15 


27318.008

Many of these regulatory processes are not difficult to complete, but some are tremendously 

rigorous. Without question, the most costly and time consuming of these regulatory processes is 

the one dictated by the National Environmental Policy Act (NEPA). NEPA analyses historically 

were completed in relatively short timeframes and at acceptable costs. Unfortunately, in recent 

years, they have evolved in such a way that they may now take upwards of a decade and tens of 

millions of dollars to complete. From a project proponent's perspective, this drawn out process 

creates a number of problems. One of the most significant challenges is commodity price 

instability. Markets are dynamic, which means a proponent may propose a pipeline project at a 

particular commodity price and as the NEPA process proceeds, that price may change 

drastically. This adversely affects the original economics and potentially undermines the 

viability of projects, including C02 pipelines and projects that reduce carbon emissions and 

provide additional environmental benefits. 

As an example, Den bury Resources submitted a right-of-way (ROW) application for the Riley 

Ridge to Natrona Pipeline project in February 2013. This project is intended to transport C02 

from a source in western Wyoming to an interconnect facility in central Wyoming, for the 

purposes of use in enhanced oil recovery (EOR). At the time of their application, oil prices were 

approximately $1 05/barrel. After 4 y, years ofNEPA review, and with a current oil price of 

roughly $45/barrel, the Draft Environmental Impact Statement (EIS) has not yet been released 

for public comment. While there are a number of reasons for this, the reality is that this timeline 

has significantly delayed implementation of this project at significant cost to the project 

proponent, and the state and federal governments that stand to benefit from anticipated revenues 

from taxes and oil royalties. 

Regulatory Solutions 

I am not here this morning to suggest that NEPA be abolished, or even significantly amended. 

As you are aware, the National Environmental Policy Act of 1969 was enacted to fulfill a 

specific set of purposes, as described below: 

• Sec. 2 {42 USC§ 4321]. The purposes of this Act are: To declare a national policy which 

will encourage productive and enjoyable harmony between man and his environment; to 

promote efforts which will prevent or eliminate damage to the environment and biosphere 

and stimulate the health and welfare of man; to enrich the understanding of the 

ecological systems and natural resources important to the Nation; and to establish a 

Council on Environmental Quality. 

To fulfill its purposes, NEPA is meant to function merely as a procedural law, which requires 

that impacts of a proposed action, and alternative actions, be disclosed for the purposes of 

informing a decision. This fundamental basis of the law has eroded, which has led to NEPA 

being utilized in a prescriptive manner and to a large extent it has become a tool to either defend 

or inform litigation. I suggest that we take a step back and look at the enabling legislation that 

created NEPA and return the process to its original intent. I do not believe that we need to 

reinvent the wheel, rather I think we just need to make it round again. While this 

recommendation sounds simplistic, the reality is that it will require a significant paradigm shift 

as well as cultural changes. Reversing the inertia ofNEPA's current course will require 
16 


27318.009

significant leadership, and I submit that this committee is eminently qualified to undertake and 

accomplish this goal. 

Additionally, I suggest a foundational change to the NEPA process, which could either be 

achieved by legislative action, or through informal agency actions (e.g. manual updates, internal 

memoranda, etc.). NEPA requires a specific sequence of actions in order to reach a final 

decision. This process is initiated by a Notice of Intent and Scoping, then the Draft EIS is 

released for public comments. After comment review and edits, agencies release the Final EIS, 

and finally the Record of Decision and Agency Action. It has been my experience that far too 

many resources are devoted to these steps and not nearly enough work is done on the front end of 

projects in order to build a strong base. To illustrate my point, none of us want to live in a house 

that was built on a weak, structurally deficient foundation. This inevitably leads to schedule 

delays and increased costs on the back end. The same can be said for the NEPA process and the 

resulting environmental analysis. 

There are a number of agency activities that occur behind the scenes to prepare for the NEPA 

process, one of which is "internal scoping". This is where agency personnel work together 

internally to gather data, develop schedules, and generally inform themselves of the project 

similar to how the public informs the process during public scoping. Unfortunately, federal 

agencies do not effectively reach out to other entities that are often times much more 

knowledgeable and may have far greater insight into potential constraints that inevitably lead to 

delays. There are limitations to how this outreach can occur, which are dictated by federal law, 

however, adding this step on the front end will undoubtedly reduce the time and resources 

required to reach a decision. 

In Wyoming, we are actively developing a project that exemplifies this effort to build a strong 

foundation in order to minimize future analysis requirements. Similar to the previously 

mentioned example, we have witnessed a substantial number of projects that have been delayed 

by NEPA. As C02 regulations, oil prices, and our knowledge ofEOR potential in Wyoming 

increased we decided that it would be tremendously beneficial to our economy, the companies 

that choose to operate within our state, and our potential to manage carbon emissions to develop 

what we call the Wyoming Pipeline Corridor Initiative (WPCI). While formalizing this project 

proposal, we have coordinated with industry; local, state, and federal agencies; nongovernmental organizations; individuals that have intimate knowledge of lands within our 

borders; and other authorities with experience in the C02-EOR industry and its associated 

infrastructure demands. 

Wyoming Pipeline Corridor Initiative 

WPCI is a sound strategy to streamline the NEPA process for pipeline infrastructure, without 

compromising the integrity of the Act or its process. The WPCI is a component of Governor 

Mead's energy strategy for the State of Wyoming (http://energy.wyo.gov) and it is our goal to 

obtain federal authorization for an intrastate pipeline network (see attached). One of the primary 

purposes of the pipeline network is to connect existing oil fields suitable for EOR with C02 

sources. The C02 will be injected into existing, often "played-out" oil fields, thereby increasing 

oil production beyond conventional recovery methods with little additional surface disturbance 
17 


27318.010

while ensuring safe and permanent geologic storage of C02 in the process. Once we complete 

our EIS and the authorization is approved, companies will be able to build their infrastructure 

within the corridors in reduced time and at reduced costs, as we will have already dedicated our 

resources to completing the bulk of the NEPA analysis. Additionally, we hope to solve the ever 

present question associated with C02-EOR, which is who expends resources first --the 

developers of capture facilities or those who develop pipeline infrastructure. In this case it will 

be the State of Wyoming laying the groundwork for pipeline infrastructure. 

We have designed WPCI as a pipeline corridor network of25 segments, approximately 1,983 

miles in length, and wholly within the State of Wyoming. Approximately 1,150 miles (58%) of 

the network is expected to be located on Federal Lands, with 708 miles (62% of the federal land 

mileage) located in corridors designated or proposed in Bureau of Land Management (BLM) 

Resource Management Plans (RMP). Over 90 percent ofWPCI parallels existing pipelines. The 

Right of Way (ROW) widths will vary between 200-300 feet and be sufficient to accommodate 

a number of pipelines of varying types. 

Some of the benefits that will result from WPCI are: 

• An estimated 500 existing oil reservoirs in Wyoming are potential EOR candidates with an 

estimated production of up to 1.8 billion barrels of oil, based on current technologies. 

Additionally, 20 trillion cubic feet of C02 could be stored as a result of this enhanced 

development. 

• The WPCI will provide a large number of jobs for those building, maintaining, and operating 

pipelines and EOR fields. These jobs would likely be in Wyoming communities which have 

recently experienced significant declines in energy-related employment. The University of 

Wyoming, School of Energy Resources, estimates that 188 jobs are supported for every 

million barrels of incremental oil production, or 6. 7 jobs per million cubic feet/day of 

purchased COz. 

• Additional production of oil, gas, and liquids from EOR will generate significant royalties 

and taxes for federal, state, and local governments. 

• The WPCI provides a balanced approach of natural resource utilization and environmental 

conservation. 

• Performing the environmental analysis for the WPCI will alleviate many of the challenges 

associated with conducting environmental analyses for individual pipeline projects, which is 

currently a significant barrier to infrastructure expansion. Individual projects proposed in the 

WPCI corridors will undergo environmental analysis, but in a shortened timeframe and at 

reduced costs to proponents, due to the robust NEPA analysis that will be completed to 

authorize WPCI. 

• The WPCI will be located almost entirely within existing ROW corridors, designated in 

BLM RMPs and/or adjacent to existing pipeline infrastructure. This will minimize the 

proliferation oflinear disturbances; and reduce impacts to wildlife and their habitats, 

culturally significant properties, and other sensitive resources. 
18 


27318.011

• A sufficiently wide ROW corridor will provide for future location of product pipelines (oil, 

gas, liquids, etc,) with minimal additional environmental analysis needed and encourage 

colocation of new pipelines. 

• EOR will occur primarily in established oil fields in Wyoming which have historical 

disturbance, extending the field's life and providing an opportunity to improve its 

reclamation status at the end of its productive life. 

To date, we have worked on baseline development ofWPCI for approximately 4 years. We have 

produced and allowed stakeholder review of corridor mapping, a Plan of Development, and 

baseline impact analyses. We are now anxiously awaiting the approval from the Bureau of Land 

Management (BLM) to begin the NEPA process. Once finalized, WPCI will be a model that can 

be followed by any states interested in streamlining NEPA work. 

ffi- EOR Working Group 

In addition to the work outlined previously, Governor Mead has sponsored or co-sponsored 

several additional initiatives for the support of CCUS and C02-EOR. In 2015, Governor Mead 

and Montana Governor Bullock, acting as Chair and Vice-Chair of the Western Governors' 

Association, released a Policy Resolution for Enhanced Oil Recovery (see attached). As a result 

of that resolution, and the interest it received, they subsequently co-convened a multi-state, C02-

EOR Working Group. Our Working Group is comprised of 14 states, and growing, with 

bipartisan leadership and we are working toward development of policies that incentivize 

deployment ofCCUS technologies. 

To date, we have released three reports that describe potential carbon capture incentives, 

recommendations to streamline and finance pipeline development, and potential opportunities to 

address market and grid challenges associated with CCUS. Links to these reports are provided 

below: 

• Putting the Puzzle Together: State and Federal Policy Drivers for Growing America's 

Carbon Capture and C02-EOR Industry http://www.bcltercn~.org/EORpoli.Qy 

• 21" Century Energy Infrastructure: Policy Recommendations for American C02 Pipeline 

Networks http://www.betlerenergy.org/ American C02 Pipeline Infrastmcture 

• Electricity Market Design and Carbon Capture Technology: The Opportunities and the 

Challenges http://www.betterenergy.org/publications/electricity-market-design-andcarbon-capture-technologv 

Finally, we have supported legislative efforts to further deploy CCUS technology. We believe 

that legislation to extend and improve 45Q tax credits is essential for further deployment of the 

carbon capture industry. These tax credits will further bolster deployment, by providing added 

financial certainty that currently does not exist. The resulting symbiotic relationship of 
19 


27318.012

regulatory and financial certainty will in the end lead to our desired results of continued 

development of fossil fuels, with added storage of C02, and more stable and diverse economies. 

Once again, I appreciate the opportunity to present this testimony today, and I am happy to 

answer any questions. Thank you. 
20 


27318.013

e C02 Producing Wel!s 

Pow-erP!ants 

Extstlng F~tds Suitable for C02 F1t~oding 

~Trunk Corridor 

latera! Corddor 

C02 Prodvcit'lg Fields 
21 


27318.014

WESTERN 

GOVERNORS' 

ASSOCIATION 

A. BACKGROUND 

Western Governors' Association 

Policy Resolution 2015-06 

Enhanced Oil Recovery 

1. Enhanced oil recovery (EOR), using carbon dioxide (C02), when performed 

appropriately and responsibly offers a safe and commercially proven method of 

domestic oil production. The U.S. oil and gas industry, which pioneered the C02 EOR 

process in West Texas in 1972, is the world leader. Over four decades, the EOR industry 

has captured, transported, and injected large volumes of CO, for oil recovery with no 

major accidents, serious injuries or fatalities reported. 

2. The C02 EOR process works by injecting CO, obtained from natural and anthropogenic 

sources into existing oil fields- often referred to as "brownfields"- to free up additional 

crude trapped in rock formations. This CO, "flooding" can result in recovery of about 

twenty percent of the original oil in place.' CO, flooding utilizes existing assets to 

recover significant additional resources stimulating the economy and minimizing 

surface disturbance that new exploration and development projects necessarily entail. 

In addition, many areas favorable for C02 application exist where new or continued 

significant drilling activity is unlikely to occur at a meaningful scale for years, if ever. 

3. As of 2013, EOR using CO, produced approximately 280,000 barrels of domestic oil per 

day, or four percent of U.S. crude oil production.' 

4. America has an estimated 21.4 billion barrels of oil, requiring 8.9 billion metric tons of 

C02, that could be economically recovered with today's EOR technologies. With 

advances in technology, 63.3 billion barrels of oil, requiring 16.2 billion metric tons of 

C02, could be economically recovered, which is roughly double current U.S. proven 

reserves3. 

5. EOR enhances our nation's energy and fiscal security by reducing dependence on 

foreign oil, often imported from unstable and hostile regimes. It allows reduction of our 

trade deficit by keeping dollars now spent on oil imports here at home and at work in 

the U.S. economy. 

1 National Energy Technology Laboratory- Untapped Domestic Energy Supply and Long Term Carbon Storage Solution 

2 Energy Information Administration- Annual Energy Outlook 2015 3 U.S. Department of Energy, National Energy Technology Laboratory 

Western Governors' Association Policy Resolution 2015- 06 
22 


27318.015

6. Coal and oil production and utilization and other industrial processes are a vital 

component of many western states' economies. EOR provides a long-term path for 

continued low-carbon production and use of our nation's coal and oil resources and 

presents an opportunity for state and local governments to stimulate economic activity 

and realize additional revenue at a time when most governments face significant fiscal 

challenges. 

7. C02 is currently limited in availability from high-volume sources needed for EORnatural sources will not close a supply gap projected to grow. Further, COz capture and 

pipeline transport capacity to oil fields is not sufficient. 

8. C02 capture equipment, installed on a broad range of industrial processes, has the 

potential to supply significant volumes of C02 to the EOR industry enabling the U.S. to 

achieve significant net carbon reductions through the sequestration of C0z. 4 

9. The U.S. has the opportunity to provide global leadership in carbon capture research 

and technology development, hydrocarbon recovery and geologic storage research and 

technologies, manufacturing, engineering and other services. 

B. GOVERNORS' POLICY STATEMENT 

1. In recognition of the environmental and economic benefits of EOR, Western Governors 

support policies and incentives that advance investment in EOR projects, infrastructure, 

technology and research. 

2. Western Governors support efforts to increase the awareness of the many benefits C02 

EOR. 

3. In order to expand deployment of C02 capture at power plants and other industrial 

sources, the President and Congress should enact federal incentives to increase C02 

supply available for the oil industry to purchase and use in EOR. Federal incentives 

have the potential to leverage private and state investment, harness the ingenuity of 

entrepreneurs and capitalize on billions of dollars' worth of DOE-sponsored research 

and development to enable new commercial carbon capture and pipeline projects. 

4 As of 2014, approximately 13.6 million metric tons of C02 was captured that would otherwise be released into the 

atmosphere has been sequestered as a result of EOR (U.S. Department of Energy- Quadrennial Energy Review). 

Over the life of a project, for every 2.5 barrels of oil produced, it is estimated that a typical commercial EOR project 

can safely prevent one metric ton of CCh from entering the atmosphere (Kuuskraa, Godec, Dipietro- Energy 

Procedia). Further, the volume that could be captured and sequestered from industrial facilities and power plants to 

support economically recoverable EOR reserves could be 8.9 to 16.2 billion metric tons of CO:z. This is equal to the 

total U.S. C02 production from fossil fuel electricity generation for approximately 4 to 8 years (EPA 2015 Green 

House Gas Inventory). 

Western Governors' Association 2of3 Policy Resolution 2015 - 06 
23 


27318.016

4. Federal policies aimed to limit C02 emissions should promote, and not impede, 

development and deployment of C02 capture and commoditization. Federal regulations 

should allow states to create programs tailored to individual state needs, industries and 

economies and recognize C02 sequestration that results from EOR in meeting federal 

regulatory objectives. As such, EPA should abide by principles already established by 

the Agency in its regulations promulgated to ensure the long-term storage of COz in 

different geologic formations. 

C. GOVERNORS' MANAGEMENT DIRECTIVE 

I. The Governors direct the WGA staff, where appropriate, to work with EPA and other 

federal agencies, Congressional committees of jurisdiction, and the Executive Branch to 

achieve the objectives of this resolution including funding, subject to the appropriation 

process, based on a prioritization of needs. 

2. Additionally the Governors direct the WGA staff to develop, as appropriate and timely, 

detailed annual work plans to advance the policy positions and goals contained in this 

resolution. Those work plans shall be presented to, and approved by, Western 

Governors prior to implementation. WGA staff shall keep the Governors informed, on a 

regular basis, of their progress in implementing approved annual work plans. 

Western Governors enact new policy resolutions and amend existing resolutions on a bi-annual basis. Please 

consult westgov.orgjpolicies for the most current copy of a resolution and a list of all current WGA policy 

resolutions. 

Western Governors' Association Policy Resolution 2015- 06 
24 


27318.017

Senate Environment and Public Works Committee 

hearing entitled, "Expanding and Accelerating the Deployment and Use of Carbon 

Capture, Utilization, and Sequestration," 

Wednesday, September 13,2017 

Questions for the Record for Mr. Matthew Fry 

Chairman Barrasso: 

1. Please list all the federal environmental statutes and regulations that you have evaluated 

in developing the Wyoming Pipeline Corridor initiative. Which requirements do you 

anticipate will be most burdensome in the development of C02 pipelines? Are there 

process-related reforms that would ease those burdens while maintaining environmental 

protection? 

Response: 

While developing the Wyoming Pipeline Corridor Initiative (WPCI), I have evaluated the 

following federal environmental statutes and regulations: 

• The National Environmental Policy Act of 1962-42 U.S.C. 4321 et seq. 

• Mineral Leasing Act of 1920, Section 28 30 U.S.C 185 

• Antiquities Act of 1906- 16 U.S.C. Section 431-433 

• Archaeological Resources Public Protection Act of 1979 16 U.S.C. Section 470aa 

• Endangered Species Act of 1973 16 U.S.C. 1531 et seq. 

• Federal Land Policy and Management Act- 43 U.S.C 1701 

• Federal Highway Administration- 23 CFR Part 645 Subpart B23, U.S.C. Sections 116, 

123 

• U.S. Army Corps of Engineers; Section 404 of the Clean Water Act of \972-40 CFR 

122-123,33 U.S.C. Section 1344; 33 CFR Parts 323,325 

• Bureau of Alcohol, Tobacco and Firearms; Section 1102(a) of the Organized Crime 

Control Act of 1970- 18 U.S.C. Section 841-848; 27 CFR Part 181 

• Advisory Council on Historic Preservation; Section 106 National Historic Preservation 

Act- 36 CFR Part 800, 16 U.S.C. 470 

• BLM Manual 9011.1, Guidelines for Conducting Chemical Pest Control Program 

There may be additional federal regulatory requirements as we move further into the process of 

authorizing WPCI. The WPCI will also fall under the regulatory authority of various state and 

local statutes, regulations, and planning requirements. 

The National Environmental Policy Act (NEP A) requirements will be the most burdensome in 

development of C02 pipelines, where a federal nexus exists that triggers the Act. However, 

when WPCI is completed, other states could follow our example to develop corridor systems of 

their own, thus streamlining project level NEP A in their own states. Where there are no NEP A 

requirements (e.g. no federal lands), the requirements of the National Historic Preservation Act 

or Section 404 of the Clean Water Act may create the greatest challenges, although not nearly as 

great as NEP A. If Government entities and project developers begin to better plan their project 
25 


27318.018

footprints and public outreach, they will likely expedite their authorization timing substantially. 

One possible procedural reform may be required pre-scoping of projects. This could require a 

concerted effort to gain input from affected federal, state, and local agencies, directly impacted 

landowners, and the general public on potential project routing constraints. This early planning 

should better inform project development so that the steps of the formal NEP A process will be 

streamlined. 

2. In your written testimony, you said that projects in Wyoming have been hampered by the 

National Environmental Policy Act (NEP A) process. Could you elaborate on those 

examples? Would the changes outlined in your answer above address those challenges? 

Response: 

I provided an example of the Denbury Pipeline in my written testimony. I believe that better 

outreach and constraints analysis could have reduced the timeframe required to develop their 

NEP A analysis. As a specific example, BLM conducts "scoping meetings" as their mechanism 

to provide and gain information from interested parties about projects. Four scoping meetings 

were held in different Wyoming towns on consecutive days. According to the Scoping Report, a 

total of 30 individuals attended these meetings. The proposed pipeline is approximately 250 

miles in length. I suggest that a concerted effort for better outreach and utilizing better forums 

could inform project design in a way that minimizes challenges on the back end. 

3. The Wyoming Pipeline Corridor Initiative seeks to streamline environmental review by 

performing a NEP A analysis on a corridor-wide basis, thereby reducing the amount of 

time required for the environmental review of each individual C02 pipeline segment. 

What do you see as the main barriers to other states performing similar corridor-wide 

environmental analyses? Could the federal government provide better assistance to states 

that might be considering replicating Wyoming's efforts? 

Response: 

I do not believe there are any true barriers for other states to complete a corridor system, similar 

to WPCI. However, there will be challenges that they must overcome. First, adequate 

experienced staff, technology, and NEPA analyses are costly. Any funding assistance that can 

be provided will be extremely beneficial. Also, as I mentioned, this project is an "out-of-thebox" approach to infrastructure development. Undertaking a project this large and different has 

apparently been daunting to the Bureau of Land Management (BLM). As a result, I have had 

and continue to have difficulty moving WPCI along through their administrative process. 

Anything the federal government can do to motivate BLM, and other agencies, to prioritize 

completion of projects like WPCI will be tremendously useful. 
26 


27318.019

Senator Sullivan: 

4. I have been exploring ways we could broadly reform NEP A to ensure that environmental 

reviews are competed in 2 to 3 years and not I 0. Do you think that the United States would 

see a marked increase of pipelines and facilities like the Petra Nova project ifNEPA were 

amended to bring it back within its original confines-a set of procedural requirements 

ensure that the environmental effects of projects are considered and shared with the 

public? 

Response: 

I think we would see development of more projects ifNEPA analyses were completed within their 

original confines. First, more foundational and functional analyses would greatly reduce the costs 

ofNEP A. Additionally, reducing the time it takes to actually complete the NEPA process provides 

an additional level of financial certainty for project proponents. While market forecasts have their 

limitations, it is likely more beneficial for financiers to use 2-3 year market forecasts, rather than 

I 0 year forecasts. 

Response: 

a. In your testimony you reference the judicial and regulatory inertia that has made 

NEP A less of an environmental policy, but instead a too/for delay and litigation. 

In your experience, how has NEP A in its current form delayed or stopped 

environmentally sound and economically beneficial infrastructure? 

I believe that NEP A, in its current form stretches too broadly and is more focused on the 

development of a "litigation proof' administrative record, rather than a true impacts analysis. 

There needs to be a substantive discussion amongst all those interested in environmental analyses 

to determine how far the zone of impact from a project truly reaches. Unfortunately, as NEPA 

documents reach farther from project footprints, the power of their analyses reduces accordingly. 

This has resulted in significant increases in time/costs and greater ambiguity in the impacts 

disclosed. 

Response: 

b. I recently introduced a billS. 1756 the Rebuild America Now Act which among 

other provisions would modernize NEPA and codify certain principles the 

administration has been pursuing via CEQ regulations. Most of our current 

streamlining of environmental reviews have focused only on specific titles of the 

US. Code, e.g.. title 23, but have not included all infrastructure pr(Jjects, such as 

pipelines, mines, and energy projects. Given your experiences how valuable is it 

for us to look at NEPA changes that go beyond purely transportation projects? 

I believe that all of these projects have similar NEPA challenges. Accordingly, to include pipelines 

in the broader infrastructure discussion would be tremendously beneficial. 
27 


27318.020

Senator Whitehouse: 

C02 Pipelines 

5. At the hearing, witnesses agreed that a major hurdle for CCUS projects is capital 

.financing and upfront costs. It was also discussed that C02 pipeline infrastructure buildout is needed to facilitate the transport ofC02for reuse and to improve the financing of 

projects. 

a. What specific federal policies would facilitate the construction of C02 pipelines? 

Response: 

As you mention, policies that provide greater financial certainty will greatly influence 

construction of C02 pipelines. Passage of 45Q legislation will provide a powerful incentive on 

this front. Additionally, policies that streamline regulatory approvals, without reducing their 

quantitative value, will also facilitate infrastructure development. A more efficient and effective 

NEP A process, in geographic regions that require them, would be advantageous. In all regions 

of the country, a concerted, proactive planning process to develop and site pipeline corridors 

would reduce the back end challenges of pipeline development. 

Response: 

b. Is it true that a majority of new pipelines could be built within existing interstate 

pipeline corridors? Or will C02 pipeline infrastructure build-out occur in areas 

that will require extensive NEPA requirements? 

Unfortunately, most new pipelines cannot be built within existing pipeline corridors. There has 

been one large scale effort by federal agencies to develop interstate pipeline corridors. Under 

Section 368 of the 2005 Energy Policy Act, the Departments oflnterior and Energy developed 

the West Wide Energy Corridor (WWEC). While fundamentally the WWEC was a good idea, it 

was completed without adequate outreach to identify functional corridors. Additionally, the 

scale of the analysis was too coarse. As a result, the WWEC has limited utility. If there is not a 

broader effort to administratively authorize corridors, similar to Wyoming's WPCI, extensive 

NEP A will be required for each individual pipeline project. 
28 

Senator BARRASSO. Thank you so much for your testimony. 

Mr. GREESON. 

STATEMENT OF DAVID GREESON, VICE PRESIDENT OF 

DEVELOPMENT, NRG ENERGY 

Mr. GREESON. Thank you, Chairman Barrasso and Ranking 

Member Carper, and Committee members. My name is David 

Greeson. I am Vice President of Development for NRG Energy. I 

am based in Houston, Texas, where I have spent the last 7 years 

developing the world’s largest carbon capture system attached to a 

power plant. The project is called Petra Nova, and I am happy to 

report that it came online on time and on budget thanks to a lot 

of hard work by NRG and our partners, JX and Hilcorp. 

As I appear before you today, this $1 billion project is capturing 

5,000 tons per day of CO2 , which is the equivalent of taking 

350,000 cars off the highways of the U.S. And it is doing it without 

increasing the cost of electricity to consumers in Texas. We 

achieved this success despite numerous challenges that come with 

deploying the first-of-a-kind technology. The biggest hurdle was, 

and remains, the up-front capital cost. And I will refer you to my 

written testimony for a discussion of what the industry is doing to 

reduce those costs. 

But I would like to take this opportunity to thank Congress and 

particularly the members of this Committee who have supported 

DOE’s efforts to address the up-front costs, such as the Clean Coal 

Power Initiative, which funded $190 million of our $1 billion 

project. DOE’s grant and the participation of the DOE was essential to the success of our project. 

I would like to also thank the members of this Committee that 

are supporting the 45Q program improvements. We feel like this 

change to the program will help level the playing field between carbon capture and other low carbon technologies such as wind and 

solar. 

But up-front cost was not our only obstacle. We also faced a 

number of licensing and permitting challenges, as well. For example, during the financing of the project, we had to deal with confusion in the industry over whether EPA’s Class VI versus Class II 

injection well standards would apply. If Class VI had applied to our 

project, it would have added over $100 million to the cost of this 

project; a huge sum. 

Thankfully, EPA eventually issued a guidance paper that clarified the Class II standard, that we have used for over 40 years in 

the U.S. and has served us very well, will continue to be the standard. 

But a much bigger concern was the NSR rules of the Clean Air 

Act. They caused us a great deal of heartache and ultimately cost 

a lot of dollars to circumnavigate. Carbon capture systems need 

steam, and when considering our options to provide steam, it would 

seem logical that we would take that steam from the boiler, since 

it is already making a lot of steam for electric purposes, but modifying the boiler to provide that steam can cause a lot of permitting 

problems. You see, our coal plant is 35 years old. It has a complete 

suite of environmental controls already, for NOx, SOx, particulate, 

29 

and mercury, and has an exemplary environmental performance 

record. 

Nevertheless, control technologies have evolved over the years, 

and these older systems may not be sufficient to pass a New Source 

Review. So, if we had made modifications to the boiler to provide 

steam to carbon capture, we might have triggered the need for a 

New Source Review, and we are not sure that all of the systems 

on the plant would have been up to the New Source Review standard. 

Since the cost and schedule impacts of a New Source Review 

were just not knowable in advance, it was impossible for us to 

build a project plan based on any path forward that relied on New 

Source Review, so we decided to go a different way. We supplied 

the steam through a $100 million cogeneration system. This system 

also provided electricity, so there were some offsets to this up-front 

cost, but in the end the up-front cost was substantial and it hurt 

the project economics. 

So it was a shame that we missed the opportunity to save money 

by sourcing steam from the boiler. But an idea that might preserve 

that option for future carbon capture projects would be to provide 

an NSR exemption for the existing plant systems when the project 

being permitted is a new emission control system. In this way, the 

truly new facilities would be fully vetted through the permitting 

process without putting risk on the systems that are already permitted and running. 

You know, it is ironic that the New Source Review rules are 

meant to improve air quality, but in practice they actually discourage plant owners from considering major improvements, including 

environmental improvements. 

In the first 8 months of operation, we have injected almost 1 million tons of CO2 into the oil field, and that CO2 would have otherwise been emitted to the atmosphere. 

For the next projects, capital costs will continue to be a barrier 

to entry and be the largest barrier to entry, and I can assure you 

that the industry is working on those. But environmental rules can 

and do hinder the deployment of future systems. 

Thank you, and I look forward to the Q&A. 

[The prepared statement of Mr. Greeson follows:] 

30 


27318.021

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

Written Testimony of David Greeson 

Vice President, Development 

NRG Energy, Inc. 

My name is David Greeson, Vice President of Development for NRG Energy, Inc. I have 36 years of 

experience in the electric power industry in both regulated utilities and independent power companies. I 

have developed 5 major power projects in the U.S. that total more than $3 billion of investment including 

the $1 billion Petra Nova Carbon Capture and Enhance Oil Recovery project that I'll be speaking about 

today. 

The Petra Nova project began as an initiative by NRG to find a way to de-carbonize our coal-fired 

generation fleet and do so without increasing the cost of electricity. When we began this project in 2009, 

there were good reasons to believe that policies were coming that would make it difficult for coal-fired 

power plants without carbon capture to continue to deliver the value that our customers and 

shareholders had come to expect. 

Everything we do at NRG is subject to competition. We are not a utility with captive customers, rather we 

must win each customer on a competitive, best-value basis compared to their other choices. Therefore, 

the final design of the Petra Nova project was guided by two constraints: 

The project could not increase the cost to produce electricity from the host coal unit or negatively 

impact its ability to participate in the competitive Texas electric market. 

• Enhanced oil recovery (EOR) was (and is still today) the only known way to simultaneously (a) 

handle significant volumes of co, to be captured from the coal-fired power plant and (2) create a 

revenue stream that could off-set the cost of building and operating carbon capture absent a price 

on carbon emissions. 

Today, after seven years of diligent work by NRG, our partners, and our contractors, the plant is on-line 

capturing more than 5,000 tons per day of co, which is the equivalent of taking 350,000 cars off of the 

road. Thanks to a lot of planning, preparation, and persistence I'm proud to report that the project was 

on-time and on-budget which is an amazing accomplishment for a first of its kind deployment of a 

technology at full commercial scale. The plant is operating as designed which means that we now have a 

coal-fired power plant that has the same carbon footprint as a natural gas-fired unit. 

As you can see from slide 5 in the attachment to this testimony, the project is really five projects in one: 

1. Design and build the facilities needed to interface with the host coal-fired plant in a way that did 

not impact its cost or its operations. 

2. Install a carbon capture technology that had never been built at this scale before and had many 

design improvements that were not in the one-tenth scale unit built several years earlier. 

3. Obtain rights of way and construct an 81-mile co, pipeline without the power to condemn or 

expropriate private property. 

4. Prepare a legacy oil field that had been in production since the 1930s for C02 operations by 

finding and plugging virtually all the existing wells, drilling about 300 new wells, and installing 

two large processing plants on the surface to handle the new oil production. 

5. Re-establish a pipeline link to the crude oil market since the previous facilities had been 

abandoned years ago. 
31 


27318.022

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

The carbon capture system starts by pre-treating the flue gas by cooling it and removing any remaining 

trace amounts of sulfur in a vessel called the quencher. Next, treated flue gas is blown upward through 

the 340 foot tall absorber tower where the co, comes into contact with a liquid solvent and dissolves into 

the solvent. The solvent, now laden with co,, is pumped to a closed vessel where it is heated by steam 

which causes the co, to come out of solution as a pure gas. Now segregated, co, is compressed and 

transported down an 81-mile pipeline where it is injected into the oil field. I've included a picture of the 

Petra Nova CCS facility in the attachment. 

Once the co, arrives at the oil field it is injected into the oil-bearing formation where it acts as a solvent, 

dissolving into the otherwise unrecoverable oil and lowering its viscosity. This viscosity change allows 

stubborn oil that is clinging to the surface of the rock in the reservoir to flow freely to wells to be 

recovered. At the surface, the oil-water-co, mixture is separated and the oil is sold to the market. The 

produced water is re-injected into the oil formation and the recovered co, is recompressed and likewise 

re-injected. With each cycle of injecting and producing fluids, a portion of the C02 remains in the oil 

formation permanently and as a result, all the injected co, is ultimately sequestered in the formation. 

NRG considers itself very fortunate to have great partners in this project, beginning with the US DOE in 

2010 when we finalized the grant agreement. Hilcorp joined the project in 2011 as our oil field operator 

and designer/operator of the enhanced oil recovery system. JX Nippon Oil and Gas Exploration, which is 

the largest oil company in Japan, became NRG's 50-50 partner in 2014 after a year and a half of working 

on the project pro bono. And finally, the Japanese Government through its Japanese Bank for 

International Cooperation (JBIC) and Nippon Export and Investment Insurance agencies (NEXI) made a 

limited recourse loan to the project to complete the capital requirements. 

The project has been in full commercial operations for 8 months now. I am pleased to report that all 

systems are working well and oil production is rising sharply. In December of 2016 just 8 months ago this 

oil field was producing less than 300 barrels of oil per day. Today, it is producing more than 4,000 barrels 

per day. 

Please keep in mind that NRG's power plant does not pay for any of the cost of carbon capture and 

enhanced oil recovery. Even the steam and power needed by the carbon capture system is provided by 

Petra Nova's own captive cogeneration system (as I'll discuss in more detail below, we elected to build a 

dedicated cogeneration system due to Clean Air Act New Source Review concerns). 

NSR Discussion 

Carbon capture systems need steam. The logical best place to supply that steam is to modify the coal 

plant and extract the amount of steam that is needed. However, in cases where a company is looking to 

install a carbon capture system onto an existing unit, this may not be the best approach. Environmental 

control technology continues to progress and New Source Review (NSR) rules can trigger a requirement 

to bring older control systems up to modern standards, thereby adding significant costs for minimal 

environmental benefit. 

Ironically, while the NSR rules are meant to improve air quality, in practice they actually discourage plant 

owners from considering major improvements- including environmental improvements. 
32 


27318.023

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

The host coal unit ultimately selected for the Petra Nova project was NRG's Parish Unit 8. This 640MW 

unit has a complete suite of environmental controls: low sulfur fuel, low NOx burners, Selective Catalytic 

Reduction system (SCR) for NOx control, bag house for particulates, Activated Carbon Injection (ACI) for 

mercury control, and a 1982 vintage flue gas desulfurization system (FGD) for SOx control. Unit 8 is an 

excellent environmental performing unit nevertheless, it is a 35 year old plant and control technologies 

have incrementally improved since Unit 8's systems were installed. 

As we put the project together, we had to make decisions and set directions that would play out over 

several years with costly implications if those directions had to change. Despite Unit 8's relatively 

modern controls and stellar environmental performance, the NSR process would have subjected NRG to 

the possibility of expensive modifications. Since Petra Nova would have to bear the cost and schedule 

risk of such modifications and since the economics of carbon capture were already extremely 

challenged, we were forced to find an approach that avoided the possibility of an NSR. 

We believe modest changes to the NSR rules could help achieve the intent of the program. Congress 

should consider changes that would incentivize more CCS rather than discourage these investments. Such 

changes could preserve the ability for the coal-fired unit to continue to provide safe, reliable, and 

economic electricity to the market, without imposing unnecessary risks and capital costs. Such changes 

should allow: (1) an exemption from the NSR process for all existing plant systems when a new emissions 

control system is being added, (2) an NSR exemption for changes in operations designed to provide 

parasitic load (e.g. increased fuel burns) that do not increase emissions or which can be off-set by use of 

system-wide or facility-wide emissions netting, including shutdowns or curtailments at other facilities, (3) 

longer time periods for contemporaneous netting (e.g., 10 years versus 5 years), and (3) broader 

exclusions for modifications to the host coal unit for efficiency improvements. 

In the end, because of the existing NSR rules, we elected to build a stand-alone gas-fired cogeneration 

system at a cost of about $100 million to provide steam and electricity for the Petra Nova project. While 

the upfront cost was substantial and hurt project economics, it was at least partially off-set by (a) the 

ability to sell excess electricity in the Texas electric market and (b) the efficiency of the cogeneration 

system to allow us to save some money to help pay for the system. 

I look expectantly to the future of CCS in the U.S. as we continue to lead the world. The U.S. is blessed 

with plenty of mature oil fields amenable to CO,-EOR. Furthermore, a significant amount of the nation's 

coal-fired generation fleet is still young enough to warrant the investment needed for coal to take its place 

in the sustainable energy future. Unfortunately, upfront capital costs remains a major hurdle and federal 

subsidies to wind and solar (clean coal's competitors) further stack the deck against CCS, but there is 

reason for optimism. Congress is considering measures to bring parity to low carbon technologies through 

changes in the 45Q incentive program. Also, the industry is doing its part by continuing to find ways to 

reduce the cost to build amine systems like the Petra Nova project. We also have exciting innovations in 

membranes that are now out of the lab and are being tested in small field trials. And finally, new 

formulations of solvents may be commercially ready in 3-5 years that could significantly reduce the size 

of the capture system and thereby reduce the cost. 

Thank you. 
33 


27318.024

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

staternent 
34 


27318.025

Testimony of David Greeson 

NRG Energy 

Petra Nova project 
35 


27318.026

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

Carbon Works 

from an existing 

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system to strip out the CO: 

Transport CO, to a n<?arb)t oil fiBici, 

to produce othenNise 

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cl transporting the reco·.;ere:d oil 
36 


27318.027

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

C02 Pipeline Route 

Petra Nova 

Carbon Capture 

Site 

Flatterrain 

and flat 

area 
37 


27318.028

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

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38 


27318.029

Testimony of David Greeson 

NRG Energy 

Petra Nova project 

Commercial Structure 

Petra Nova Carbon 

Our Partners 
39 


27318.030

Senate Environment and Public Works Committee 

hearing entitled, "Expanding and Accelerating the Deployment and Use of Carbon 

Capture, Utilization, and Sequestration," 

Wednesday, September 13,2017 

Questions for the Record for Mr. David Greeson 

Chairman Barrasso: 

1. During the hearing, all witnesses agreed that financing is a key impediment to CCUS 

deployment. Do you believe it is important to examine ways to lessen regulatory barriers 

that might hold back the full deployment of these technologies at the same time as the 

federal government examines financing issues? 

a. Yes, lessening regulatory barriers could help reduce the administrative cost of 

CCUS and reduce the time needed to deploy these projects. 

2. Do you agree that 45Q tax credit expansion is an effective way of producing an 

additional revenue stream for CCUS projects? 

a. Yes, I believe the proposed changes to the 45Q program will lead to new CCUS 

projects. 

3. Do you agree with Mr. Fry's testimony that development of additional C02 pipeline 

infrastructure is essential for maximizing the use of enhanced oil recovery (EOR) in the 

United States? Would additional C02 pipeline infrastructure support the continued future 

deployment ofEOR as well as other potential commercial uses of C02? If so, what can 

the federal government do to streamline the regulatory approval processes for C02 

pipelines? 

a. I agree with Mr. Fry that pipeline infrastructure connecting C02 sources (power 

plants and certain large industrials) with C02 sinks large enough to safely store 

meaningful volumes of C02 (enhanced oil recovery projects) is essential to widespread deployment of CCUS in the U.S. The federal government should enact 

policies that requires existing rights of ways such as rail roads and highways be 

made available to C02 pipelines to not only lower costs, but to also minimize 

disturbing new lands. 

4. Your written testimony states that "modest changes to NSR rules could help achieve the 

intent of the program." You suggest four policy approaches: (1) "an exemption from the 

NSR process for all existing plant systems when a new emissions control system is being 

added"; (2) "an NSR exemption for changes in operations designed to provide parasitic 

load (e.g. increased fuel burns) that do not increase emissions or which can be off-set by 

use of system-wide or facility-wide emissions netting, including shutdowns or 

curtailments at other facilities"; (3) "longer time periods for contemporaneous netting 

(e.g., 10 years versus 5 years)"; and (4) "broader exclusions for modifications to the host 

coal unit for efficiency improvements." Can you elaborate on how each of the four 
40 


27318.031

proposed changes to New Source Review (NSR) would address the challenges you 

outlined in your testimony? 

a. The NSR rules are difficult to apply with any certainty for industry, regulators, 

and public stakeholders. It is not uncommon for an NSR determination to be 

made through a public hearing process, a permit issued, and the subject facility to 

be in operation for years only to have a decision in an unrelated court case cast 

uncertainty on the facility's permit. Greater clarity on Congressional intent for 

the NSR is needed. We believe that the possible changes to the NSR program 

that, when woven together, would help reduce regulatory uncertainty and lead to 

more investment in environmental improvement: 

i. (I) Exemption for installation of new emissions controls- Many owners 

of coal-fired plants, including NRG, are looking for ways to make our 

plants competitive in the low carbon energy market of the future. For 

example, there are some really exciting new membrane technologies that 

might best be integrated into the bag house systems at our plants; however 

such a modification to the existing controls system and the method of 

operation of the power plant could be viewed as triggering an NSR. It 

should be clear in the Clean Air Act that the addition of certain 

categories of environmental control systems and the applicable 

changes in the methods of operation operating do not trigger NSR. 

ii. (2) Changes in operations to supply CCUS parasitic load- in many air 

permits for power plants a "heat input limit" is established. This is 

unfortunate in that technology continues to improve and in a 30+ year old 

plant it may be possible to upgrade combustion systems and the 

turbine/generator in a way that might largely offsets the parasitic load of a 

carbon capture system. Further, power plant owners should have the 

ability to net emissions across all their units in an air shed or at the very 

least all the units at a common facility. It should be clear in the Clean 

Air Act that efficiency improvements and the applicable heat input 

increases do not trigger NSR- especially if the increases can be netted 

with reduced operations at other company facilities in the same air 

shed. State and Federal environmental agencies have a long history of 

relying on air quality models to demonstrate air quality improvements 

when considering multiple sources in an air shed, the same philosophy 

could be applied to determine NSR is not applicable (e.g., emissions 

netting across multiple units and facilities). 

iii. (3) Longer netting period- In the power industry, the ability to net 

emissions with reductions in operations is allowed on a 5-year look-back 

basis. Other industries are allowed a 10-year look-back. Given the 

amount oftime it takes to plan, engineer, finance, and construct a carbon 

capture system, we believe it is appropriate to for the power industry to 

have a 1 0-year netting period as well. For example, if a carbon capture 

plant is being considered, you might keep a unit operating longer than the 

market conditions would support just to ensure that the closure of the plant 

falls within the netting window. In other words, a longer netting window 
41 


27318.032

allows operators more flexibility to close older plants especially when 

new investment is in planning. It should be clear in the Clean Air Act 

that the power industry can use a 10-year netting period. 

iv. (4) Broader exclusions for efficiency improvements There are 

exclusions in the NSR program for routine repairs. These exclusions 

should be extended to include any maintenance and life extension 

modifications made to a generating unit that is retrofitted with a carbon 

capture system. Carbon capture systems are very expensive and take years 

to develop. Even so, installing a carbon capture system could be worth the 

investment if both the power plant and the carbon capture system can be 

counted on to operate for many years to come. It should be clear in the 

Clean Air Act that modernizations and life extending maintenance 

done in connection with the installation of a carbon capture system 

docs not trigger NSR. 

5. An August 2017 report from the Department of Energy entitled, "Staff Report to the 

Secretary on Electricity Markets and Reliability," concluded that "uncertainty stemming 

from NSR creates an unnecessary burden that discourages rather than encourages 

installation of C02 emission control equipment and investments in efficiency because of 

the additional expenditures and delays associated with the permitting process."1 Beyond 

CCUS retrofits, do you agree that NSR also discourages other types of projects that 

would reduce emissions of pollutants? For example, can NSR deter efficiency projects? If 

so, do you have recommendations to ameliorate those issues and ensure that the intent of 

NSR, which is to reduce emissions, is carried out? 

a. I have personally worked on an efficiency improvement project that was 

cancelled because NSR rules would have required the installation of costly and 

unnecessary equipment that more than off-set the economic benefits of the 

efficiency project. As I stated earlier, many NSR lawsuits happen years after 

permits are issued, investments are made, and plants have been operating for 

years. 

6. Please list all the federal environmental rules you had to comply with and permits you 

had to receive in the design and construction of the Petra Nova facility. Aside from the 

Clean Air Act requirements regarding NSR that you mentioned in your written testimony, 

which rules are the most burdensome? Are there process-related reforms that would ease 

burdens while maintaining environmental protection? 

a. Federal rules and permits (note that some are administered by the State): 

i. Air Permit modification for coal-fired power plant- altering the existing 

coal unit's permit to a dual-stack configuration 

1 The report is available at https://energy.gov/downloads/download-staff-report-secretaryelectricity-markets-and-reliability 
42 


27318.033

ii. Air Permits for carbon capture and cogeneration - three total permits for 

authority to construct the cogeneration system and the carbon capture unit 

iii. Air Permit - Title V operating permit for the cogeneration and the carbon 

capture unit 

iv. Wastewater permit- for treated wastewater to be returned to the lake 

v. Storm water permit- for proper treatment and discharge of storm water 

vi. Section 404 permit- COE permit for certain portions of the pipeline 

vii. Section 10 permit- COE permit for certain portions of the pipeline 

viii. UIC Class II injection permits- for C02 injection wells in the enhanced 

oil recovery project in the oil field 

b. Aside from compliance with the Clean Air Act, the most burdensome Federal 

approvals to obtain were from the NEP A process and the Corps of Engineers. 

The requirements and procedures themselves were not overly burdensome, 

however the long delays in receiving a final decision from the agencies caused 

many problems for our financing and construction. 

c. In both cases, Congress should consider what actions are needed to shorten the 

process. 

Senator Sullivan: 

7. It took your company seven years to complete the Petra Nova Carbon Capture and Enhance 

Oil Recovery project and I agree it is impressive that you did so on time. It has long been 

my belief that the U.S. regulatory process is a burden to most energy developers, even those 

who sought to build an innovative facility designed to minimize carbon output, we heard a 

similar narrative from Mr. Fry in reference to NEP A. Could you outline a few of the 

permitting and NEP A requirements that you encountered personally that were 

counterproductive, duplicative, or unnecessary? 

a. NEP A - The rules and guidance on what constitutes an "impact" are well known 

and, as good stewards of our shareholder's money, we were careful to design the 

capture system, the pipeline, and the oil field operations in a way that had no 

unmitigated impacts. It took us 16 months and over $1 million to get the various 

agencies involved in the NEPA review to concur that we in fact had no impacts. 

b. Corps of Engineers - We needed a number of permits, consents, and 

acknowledgements from the COE, which were all ultimately granted. In working 

with the Corps it seemed to us that they lacked the personnel to respond in a timely 

manner. 

Senator Whitehouse: 

C02 Pipelines 

8. At the hearing, witnesses agreed that a major hurdle for CCUS projects is capital 

financing and upfront costs. It was also discussed that C02 pipeline infrastructure buildout is needed to facilitate the transport of C02 for reuse and to improve the financing of 

projects. 
43 


27318.034

a. What specific federal policies would facilitate the construction of C02 pipelines? 

o The federal government should enact policies that require existing rights 

of ways such as rail roads and highways be made available to C02 

pipelines to not only lower costs, but to also minimize disturbing new 

lands and the time it takes to build this infrastructure. 

b. Is it true that a majority of new pipelines could be built within existing interstate 

pipeline corridors? Or will C02 pipeline infrastructure build-out occur in areas 

that will require extensive NEPA requirements? 

o The C02 pipeline in the Petra Nova project was smaller than the large 

diameter pipes likely to be used for long-distance interstate pipelines. 

That said, our pipeline was co-located in the same right of way with other 

pipelines, electric transmission lines, and railroads for over 95% of the 81-

mile length. Based on our experience we would answer that these 

pipelines can be built in the same right of way. I note however that impact 

on previously undisturbed lands is not the only aspect of a project that 

could trigger the need for an agency to conduct a NEP A mandated review. 

So even if a pipeline is located within an existing right of way, a NEPA 

review could be triggered by other factors. 
44 

Senator BARRASSO. Thank you very much, Mr. Greeson. 

Mr. FRIEDMANN. 

STATEMENT OF S. JULIO FRIEDMANN, CEO, CARBON 

WRANGLER LLC 

Mr. FRIEDMANN. Thank you, Mr. Chairman. Thank you, Ranking 

Member Carper and all the members of the Committee. My name 

is Julio Friedmann. Thank you for inviting my testimony. I am the 

CEO of Carbon Wrangler, LLC. Until recently, I served as the Senior Advisor for Energy Innovation at the Lawrence Livermore National Laboratory, one of the DOE’s 17 national labs. From 2013 to 

2016, I served in two capacities in the Obama administration at 

the Department of Energy, first as the Deputy Assistant Secretary 

for Clean Coal and Carbon Management and, second, as the Principal Deputy Assistant Secretary for the Office of Fossil Energy. I 

have worked for something like 17 years on clean energy technology deployment and development, focusing my work on CCUS, 

mostly from my position at the National Lab. 

Clean energy demand continues to grow worldwide, with an in- vestment of nearly $400 billion in 2015 and 2016. Many governments see investment in this technology as important to transforming energy markets and claim the additional benefits from 

those investments, for example, stronger heavy industry sector, 

maintaining and growing jobs, avoiding the health consequences of 

pollution, a number of other things. In a global clean energy market, the U.S. is considering how to best invest in the power, transportation, and industrial energy sectors as they change nationally 

and globally. 

In this context, carbon capture, use, and storage, CCUS, remains 

a critically important and under-supported sector in the clean energy industry. CCUS includes carbon capture and storage, CO2 enhanced oil recovery, which was mentioned by the Chairman, CO2

conversion and use, and even carbon removal from the atmosphere. 

These different pathways provide real commercial and environmental opportunities for companies, communities, and governments. 

Recent progress on CCUS is profound. Today there are 16 commercial plants operational worldwide, including Mr. Greeson’s 

plant at Petra Nova. Six more are planned, with 22 expected to be 

operating in 2020. These include power and industrial projects, 

new build and retrofits, some for CO2 -EOR, some for saline storage mostly in North America. A third of them are in North America. Costs have come down, performance has gone up, and new 

technologies have been born that show that CCUS can be cost competitive today with other clean energy technologies in many markets. In some sectors like heavy industry, CCUS is the only available option today. 

Importantly, the challenges CCUS faces in deployment are neither fundamentally technical nor regulatory. Rather, it is that 

today there is no policy or set of policies in place that make it possible to finance a project. There is a gap between project costs and 

market prices, and tariffs that prevent private capital from flowing 

into projects. This greatly limits deployment. While there are many 

potential pathways for providing policy support, there is no market 

45 

for CCUS absent such policies. These will severely limit the number of projects, the scale of the projects, and the availability of private capital to build and deploy CCUS. It is worth noting that of 

the $2.2 trillion that flowed into the clean energy deployment sector worldwide, according to the Global CCS Institute, less than 1 

percent of that money, less than 1 percent went into CCS. 

You have my testimony. It speaks volubly about the prices and 

the costs for carbon capture and storage, where these projects are 

going, and how it can be applied in the power and industrial sector. 

It is worth noting that if there were pipelines in place right now 

and some straightforward policies, we could capture 44 million tons 

of carbon dioxide for very, very low cost today from pure streams 

of CO2 in the industrial sector. 

But I want to focus the rest of my time on the finance question. 

As I mentioned earlier, CCUS is competitive on a purely levelized 

cost of electricity basis with many, many clean power options. 

Whether it is applied to power, industrial sectors, or not, it is not 

possible to obtain the financing for the commercial projects today. 

Just can’t do it. This is chiefly because it is not possible to recoup 

the investment. 

Many clean energy technologies in the United States and elsewhere, such as wind and solar, rightly benefit from policy support. 

These include renewable portfolio standards which mandate a fraction of generation; investment and production tax credits, the ITCs 

and PTCs; feed-in tariffs, which are guaranteed price supports, 

common in Europe; development mandates, such as the Chinese 

government says when they say we are going to build 200,000 

megawatts of wind; and many other policies. 

For many years in the U.S. and other countries, policies like this 

closed the financing gap for those clean energy technologies. That 

created markets for those clean energy and have led to growth and 

jobs. None of this is contested. 

CCUS projects have no access to these policies. If they did, the 

size of those policies for other clean energy investments, such as 

the ITC, the PTC, et cetera, would be large enough to close that 

financing gap. The lack of policies that support financing limit the 

flow of private capital to CCUS projects. Similarly, they limit the 

corporate R&D, which is necessary to get dramatic price drops 

through deployment and activation. It limits VC financing in 

startups. It limits the development of human capital. It limits the 

supply chains that would go into these industries. Many ministries 

in many countries, including the United States, have called for policy parody to close the financing gap and to help create a vibrant 

CCUS market. 

I look forward to your questions and comments. Thank you for 

the opportunity to testify. 

[The prepared statement of Mr. Friedmann follows:] 

46 


27318.035

Senate Environment & Public Works Committee 

Expanding and Accelerating the Deployment and Use of Carbon 

Capture, Utilization, and Sequestration 

Dr. S. julio Friedmann, Carbon Wrangler LLC 

Written Testimony 

Thank you for inviting my testimony. My name is julio Friedmann, the CEO of Carbon 

Wrangler. Until recently, I served as the Senior Advisor for Energy Innovation at the 

Lawrence Livermore National Laboratory. From 2013 to early 2016, I served as the 

Principal Deputy Assistant Secretary for the Office of Fossil Energy at the US Department of 

Energy. I have worked for a total of 17 years on clean energy technology development and 

deployment focusing my work on CCUS, mostly from my positions at Lawrence Livermore 

National Laboratory. 

Clean energy demand continues to grow worldwide, with investment of nearly $4008 in 

2015 and 2016. Many governments see investment in clean energy technology 

development and deployment as part of their strategy to remain globally competitive in 

transforming energy markets, and claim additional benefits from those investments (e.g., 

stronger heavy industrial sector, maintaining and growing jobs, and avoid the health 

consequences of pollution). In a global clean energy market, US is considering how best to 

invest in the power, transportation, and industrial energy sectors as they change nationally 

and globally. 

In this context, carbon capture, use and storage (CCUS) remains a critically important and 

under-supported sector in the clean energy industry. CCUS includes carbon capture and 

storage (CCS), COz enhanced oil recovery (EOR), COz conversion and use (C02U), and even 

carbon removal technology (so called negative emissions approaches, which pull COz from 

the air and oceans). These different pathways provide real commercial and environmental 

opportunities for companies, communities, and governments. 

Figure 1: Operating and soon to be operating CCUS projects world-wide. Over one third of 

these are in North America. 
47 


27318.036

Recent progress in CCUS is profound. Today, 16 commercial plants operate worldwide, and 

with six more planned, 22 will be operating by 2020 (Figure 1). These include power and 

industrial projects, new build and retrofits, and both COz-EOR and saline storage, with over 

a third in North America. Costs have come down, performance has improved, and new 

technologies have been born that show that CCUS can be cost competitive today with many 

clean energy technologies in many markets. In some sectors, like heavy industry, CCUS is 

the only option available at scale today. 

Importantly, the challenges CCUS faces in deployment are neither fundamentally technical 

nor regulatory. Rather, it is that today there is no policy or set of policies in place that make 

it possible to finance CCUS projects. There is a gap between project costs and market prices 

and tariffs that prevent private capital from flowing into projects. This greatly limits 

deployments. While there are many potential pathways to providing policy support (see 

below), there is no market for CCUS absent these policies, which will severely limit the 

number of projects, the scale of projects, and availability of private capital to CCUS 

deployment. It is worth noting that of the $2.2 trillion that flowed into clean energy 

deployment world-wide, less than 1% went to CCUS. 

Current Project Review 

As noted, over 16 projects are operating in the world today, with 6 more coming online by 

2020. Together, these will inject 40 million tons of COz underground- like pulling 8 million 

cars off the road. The overwhelming majority of these projects have been completed on time 

and on budget, and have a successful high-capacity operating history. 

In addition to these projects, there are a few additional noteworthy projects for the 

Committee's consideration. 

PetraNovat: NRG, in partnership with )X Nippon and Hilcorp Energy Company, retrofit the 

W.A. Parish power plant near Houston, TX. Roughly 1.6 Million tons are captured by the 

liquid solvent technology, provided by Mitsubishi Heavy Industries, and stored during 

enhanced oil recovery. The project came in on time and on budget. The operators and 

partners say that a second project at the same site could be done for roughly 20% lower 

cost. 

Port Arthur2 and Quest3: These two industrial projects capture and store COz which is a 

byproduct of converting methane to hydrogen. This produces very low-cost, zero-carbon 

hydrogen- the cheapest in the world so far. The Air Products project at Port Arthur stores 

the C02 through EOR. Shell's project at Quest stores in a saline formation. 

China: Many CCUS projects are moving forward quickly in China. Dr. James Wood's 

testimony will explain this in some detail. However, it is worth noting that 3 large 

commercial projects are coming on line in the next four years, and that the Chinese 

Academy of Sciences has tasked a new research institute in Shanghai4 for the sole purpose 

of COz conversion to useful products. 

NetPower Pilot Plant: NetPowers is a North Carolina based company that uses "Allam 

cycle" combustion - oxygen-fired natural gas turbines that use supercritical COz as both the 

t http://www.globalccsinstitute.com/projects/petra-nova-carbon-capture-project 

z http· //www.globalccsinstitute.com/projects/air-products-steam-methane-reformer-eor-project 

3 http://www.globalccsinst!tute.com/projects/quest 

4 http://english.sari.eas.cn/ 

5 http:l/www.netpower.com 
48 


27318.037

working fluid and mass to the turbine. The Net Power system has the same cost as a natural 

gas power block, has a physical footprint, and requires no water for cooling (in some 

configurations, the plant produces water). A pilot demonstration6 near Houston has finished 

construction and begun component testing- it should be operational in fall 2017, with 

Exelon, Chicago Bridge and Iron, and Toshiba as commercial partners. 

Climeworks Direct Air Capture Plant?: A small Swiss company, Climeworks, has created 

the first commercial, for-profit project that captures C02 directly from the air. They capture 

and sell 900 tons/year of COz to an organic greenhouse. This technology is mass-producible, 

scalable, and robust. 

Carbon removal power plant: Climeworks is partnering with Reykjavik Energy in Iceland 

and Lawrence Livermore National Laboratory to make the world's first power plant with 

less-than-zero carbon emissions. Based at the Hellisheidi Geothermal Power Station8, 

Climeworks is installing their direct-air capture system. COz drawn from the air will then be 

injected into the deep basaltic rocks below the plant, part of the CarbFix project9• US 

participation will include LLNL work on the monitoring and validation of the COz injection 

as well as the life-cycle analysis of the carbon footprint. Already, the project has paying 

customers. 

Carbon Recycling International's Renewable Methanol Plant10 : Also in Iceland, Carbon 

Recycling International has built and operated a plant that converts COz to methanol. a 

chemical feedstock and transportation fuel. Using clean electricity from the Svartsengi 

geothermal power station, they make hydrogen from water and combine the renewable 

hydrogen with COz to make methanol. This fuel is sold to ferries in Europe, which use the 

methanol to power fuel cells. 

NOTE: The increased availability of low-cost, distributed clean power and heat helps to 

create new industries like Carbon Recycling International that convert COz to products. Part 

of the likely market value of these products is the low carbon footprint. If so, then the 

demand for clean energy will grow as these companies gain market share - part of a new 

carbon economy. 

Power Applications: Range of Costs and comparisons to other technologies 

CCUS has many applications, including power, heavy industry (see below), and achieving 

negative emissions. While commonly considered a "coal" power sector technology (where it 

would be most valuable in reducing emissions), it can also be applied to biomass, natural 

gas, biogas, and even fuel cell power systems. Perhaps surprisingly, the CCUS power costs 

are competitive today on an unsubsidized cost basis with many other technology options 

(Figure 2). On an unsubsidized basis for the levelized cost of electricity (LCOE)H, power 

from gas, coal. or biomass is cheaper than offshore wind, new nuclear power, rooftop solar 

PV, concentrating solar, and community solar PV with batteries in many US markets. 

6 llttps: //www.forbes.com /sites /christopherhelrnan/2017 /02/21 /revolutionary-power-plantcaptures-ali-its·carbon·ernissions-at·no-extra·cost/#Sdb22e3d402d 

7 http://www.climeworks.com/ 

a http://www.onpower.is/about-us 

9 https://www.or.is/english/carbfix-project 

1o http://carbonrecycling.is/ 

11 Lazard, 2016. Levelized cost of electricity analysis -version 10.0. 

https: I lwww .lazard.com /perspective /level ized -cost-of-energy -analysis-1 0 0 I 
49 


27318.038

Res. Rooftop Solar PV 

Comm. Rooftop Sotar PV 

Community So-lar PV 

Utltity PV {Crystal) 

Utillty PV {Thin Film} 

Utility Solar Thermal 

FueiCetl 

Mlt:roturbine 

Geothermal 

Biomass 

Wind 

Energy Efficiency 

PV+Storage {+$30-40/MW·hr) 

<> 0 PV+Storage 

(+$30-40/MW-hr} 

No thermal 

<) storage 

rnesel Redp .~~~ .......... ~ . .c .•••. " ····~····· .............. _ .. ~ ..................................... ~-····-~~· 

NG Retip 

Gas Peaker 

JGCC 

Nuclear 

Coal 

NG Comb. Cycle 1 

$0 

mstr.Gen. 

:1li)l 

With CCS {SJF} 

$100 LCOE ($/MW-hr) 

$200 

$2.50/gdiesel $2.00/MBTU coal $350 NG 

$300 

'-::c:---:::-~--=--~:'::":'--:----~··-·-----··- Figure 2: After Lazard (2016). Red bars reflect reported costs from commercial projects and 

price estimates based on DOE and NETL reports on existing technology in the market today. 

Today, post-combustion retrofits on a supercritical coal plant using amine-based solvents is 

possible and in some cases the lowest cost pathway to decarbonization. For example, the 

PetraNova plant described above reduced 90% of the emissions from one unit without 

derating or decline in power output. Importantly, opportunities for cost reduction are major 

even with the same kit- CCUS coal plant operators in the US and Canada have publically 

stated that they could reduce costs by 20% redoing the same plant, and that the 4'h plant 

would achieve 40-50% cost savings relative to the first. 

Industrial CCUS in the US 

Many heavy industries, representing 20% of global emissions, lack other options to 

decarbonize. Cement, steel, refining (and biorefining), chemicals, and glass making are 

particularly difficult cases. For cement and steel making, much of the emissions are a direct 

consequence of fabrication chemistry. For such systems, CCUS is the only available option.12 

In many cases, though, by-product COz is highly-concentrated (e.g., for ethanol, biodiesel, 

fertilizer production, natural gas sweetening, refining, and petrochemicals). These can be 

captured and stored at relatively modest cost. In the US, the ali-in-cost ofCCS, including 

polishing, compression, transport, and storage, is less than $30 /ton COz -in some cases less 

than $20. Over 43M tonsjyear could be stored at this low cost. 13 

For this reason, perhaps unsurprisingly, most CCUS projects around the world are industrial 

projects. These include Emirates Steel (the first ultra-low C metallurgical plant), the 

Uthmaniyah refinery in Saudi Arabia, the Quest upgrader project in Alberta, the ADM 

ethanol plant in Decatur, Illinois, and the Air Products plant in Port Arthur, TX. 

12 Global CCS Institute, 2016, Understanding Industrial CCS Hubs and Clusters, 2016 

13 www.betterenergy.org/American C02 Pipeline Infrastructure 
50 


27318.039

Figure 3: High-purity C02 sources within 100 miles of potential C02 storage sites. areas 

represent oil fields; light beige areas represent saline formations for storage. Yellow dots = 

ethanol plants, purple dots fertilizer plants, red = petrochemicals plants, orange oil and gas 

refineries. 

Finance gaps and policy options 

As stated above, CCUS is competitive on a pure levelized cost basis with many clean power 

options. However, whether CCUS is applied to power, industrial or other sectors, it is not 

possible to obtain financing for commercial projects. This is chiefly because it is not possible 

to recoup a private investment given today's policy frameworks. 

Many other clean energy technologies (such as wind or solar) rightly benefit from policy 

support. These include renewable portfolio standards (mandating a fraction of generation), 

investment and production tax credits (ITCs and PTCs) which provide cash back to 

developers and operators, feed-in tariffs (guaranteed price supports, common in Europe), 

development mandates (e.g., 200,000 MW wind construction as mandated by the Chinese 

Govt), and others. For many years in the US and other countries, policies like this closed the 

gap for financing projects, and developers could recuperate their investments and pay back 

loans given the financial security of such policies. That created markets for clean energy, 

and jobs, supply chains, and wealth reaction accompanied those specific policy decisions. 

CCUS projects have no access to these policies14, If they did, the size of these policies for 

other clean energy investments would large enough to close the financing gap (see LazardlS 

14 Global CCS Institute, 2016, The Global Status of CCS, Summary Report 15 Lazard, 2016. Levelized cost of electricity analysis· version 10.0. 

https: //www .lazard.com /perspective /1 eyellzed -cost-of-energy-analysis-1 0 0 I 
51 


27318.040

and fig. 2 above). Lack of policies that support financing limit the flow of private capital into 

CCUS projects. Similarly, they limit corporate R&D investment, limit VC financing of start· 

ups, and limit the human capital and supply chains that come from projects. Many 

ministries in many countries, including the US, have called for "policy parity" to close the 

financing gap and help create a vibrant CCUS market.14,16 

Ultimately, lack of financing and a CCUS market will disadvantage US companies in the 

global marketplace. Substantial investments in R&D and projects from the governments of 

Japan, China, Germany, Canada, Norway and Saudi Arabia have supported companies and 

projects that can take advantage of emerging CCUS markets. If the US does not create 

markets for CCUS companies and projects in the US, then wealth and job creation will flow 

to other countries. 

Final thoughts 

We are at the edge of a new carbon economy- one that harnesses innovation and 

entrepreneurship to create new products, companies, and wealth through capturing and 

converting fugitive carbon into value-added products. Global carbon constraints in the 

market will convert to product value in ways that are hard to predict, but as part of an 

inexorable and inevitable trend. The global economy will increasingly value low-carbon 

products, including goods manufactured in the US with a reduced COz footprint. CCUS 

provides a low-cost pathway to both greater global competitiveness for US companies and 

for revitalizing industrial base of the US through investment and innovation. That pathway 

is ready for deployment today. 

New policies are required to help create markets for projects, vendors, operators, and 

energy services in a new carbon economy· ones that can be supported through 

conventional financial investors that would accelerate the development and deployment of 

these novel technologies and industries. 

16 Carbon Sequestration Leadership Forum, November 2015. "6th Meeting of the Carbon 

Sequestration Leadership Forum (CSLF) Ministers: Moving Beyond the First Wave of CCS 

Demonstration" http: //www.cslforum.org/publications /documents/CSLF Communique.pdf 
52 


27318.041

Senate Environment and Public Works Committee 

hearing entitled, "Expanding and Accelerating the Deployment and Use of Carbon 

Capture, Utilization, and Sequestration," 

Wednesday, September 13,2017 

Questions for the Record for Dr. Julio Friedmann 

Chairman Barrasso: 

1. In your testimony, you said that "the regulatory issues would be the next thing that people 

would look at" after closing the financing gap for CCUS. At the hearing, you stated that 

you have heard from multiple industry stakeholders that New Source Review (NSR) 

under the Clean Air Act could discourage retrofits of facilities with CCUS technology. 

Do you agree that we should examine these claims in more detail? Is it possible that NSR 

reform could help to expand deployment of CCUS technology? 

New Source Review {NSR) is a complex topic with deep jurisprudence. I do not have an opinion as to 

whether or not claims and concerns regarding uncertainty in NSR vis-a-vis potential CCUS projects 

are merited. As I and other witnesses maintained, the primary obstacle to CCUS deployment is upfront capital costs and financing, not uncertainty surrounding NSR. 

That said, one of the main benefits of a successful CCUS project is the overt reduction in emissions 

from an existing source. If operators are reluctant to undertake CCUS due to uncertainties around 

triggering NSR, then some sort of alternative or reformed process should be considered to clarify the 

existing rules, ideally in a way that continues strong controls for criteria pollutants while facilitating 

CCUS retrofits. 

2. How do public-private research partnerships, such as those through the National Carbon 

Capture Center, accelerate the deployment of clean energy technologies like CCUS? Is 

there more that the federal government could do to encourage this collaboration? 

At present, public-private partnerships are essential to accelerating the deployment of CCUS and 

other clean energy technologies. By sharing risks, responsibilities, and costs, projects {especially large 

scale-pilots, demonstration projects, and pre-commercial testbeds) can provide critically important 

technical information, develop experience, build human capital, and add confidence to evolving 

markets and investors. The National Carbon Capture Center is an excellent example of this, and has 

served many US companies who are developing technologies os well as providing standardized 

information to potential operators and investors. The same will likely prove true for the C02 

Utilization testbed being built in Gillette, WY at the Integrated Test Center. 

The Federal government could indeed do more to encourage public-private partnerships for CCUS in 

general, and the NCCC in particular: 

Create additional programs that award more testbeds through competitive solicitation. 

Potential examples could include a test-bed and standards facility for C02-based cement and 

aggregate, a National field facility for geological storage experiments and standards {as was 
53 


27318.042

proposed years ago for Teapot Dome), o public-private facility aimed at water harvesting 

from fossil fuel combustion systems, and a National algae growth and processing facility. 

• The NCCC is currently configured to test pre-combustion (mostly solvent-based}, postcombustion, and fuel-eel/ technologies for both coal and natural gas. The natural gas test 

bed could be expanded to include novel turbine designs (like NetPower's Allam Cycle system) 

and larger post-combustion gas capture programs (including larger sorbent and membrane 

systems). 

• Programs like CarbonSAFE could be expanded to build a broader public-private partnership 

system. Far example, a subset of SAFE projects could be sites to explore the creation of 

new C02 utilities. These would hove jurisdiction to raise rate-payer funds to pay for 

pipelines, and also to cover liability and monitoring issues (as well as consider primacy for 

Class VI wells for C02 injection under the EPA's underground injection control statutes). 

3. In your testimony, you said that there is an "educational and informational barrier" that 

CCUS researchers and supporters like yourself face all the time. What steps could 

overcome these educational and informational barriers and bring CCUS to the forefront 

of 21st century energy discussions? 

There are no simple answers to this challenge. Fundamentally, explaining CCUS to people involves 

showing folks what it is and gaining familiarity (my experience has been that detailed discussions of 

chemistry, hydrology, geomechanics, etc. don't help much). 

Since these facilities are typically far from population centers and transit thoroughfares, gaining 

familiarity is a challenge. Few folks visit, and many sites are neither telegenic nor dynamic. 

Over the years, many groups (e.g., Univ. Texas Bureau of Economic Geology) have developed 

curricula, training modules, K-12 experimental sets, etc. to help communicate this topic. Many 

companies and NGOs have developed short videos, children's books, and fact sheets. These do nat 

seem to hove made much progress in public communication. 

A few ideas come to mind, some of which are within the purview of the Federal Govt: 

• Study tours: Visits to multiple facilities, including field projects and national Labs, and 

featuring presentations by experts (often from local universities), have seemed to make 

progress. These could be far PUC and PSC commissioners, state and federal officials, 

regulators, investors, and media leaders. Ideally, such study tours could be regular and 

recurring, with partial federal support (e.g., from DOE). 

• Roadshow: The inverse of a study tour, a group of experts travel from place to place with 

professionally developed information, media, presentations, etc. to spend a day locally 

providing education and insight. Stops for a roads how could include state capitals, major 

universities (especially land-grant universities), and industrial centers (e.g. Houston, Detroit) 

and engage business and civic leaders directly. 

• High-profile platforms: National and international events like Davos, National Party 

Committee meetings, G20, CERA week, and others could provide platforms to educate 

decision makers on what's known about CCUS, including its benefits and economic role. 
54 


27318.043

Senator Whitehouse: 

Ocean Capture Technology 

4. Dr. Friedmann, at the hearing, you mentioned there are eight organizations working on 

removing carbon directly from the oceans. 

a. What are the names and locations of these organizations? 

b. How do these different technologies work? 

c. How might federal support help to commercialize these technologies? 

These are those organizations and companies who have worked on direct ocean capture (DOC) and have 

developed technology to extract C02 from seawater*. There may be others as well-- these are the 

main approaches I am aware of. 

Lawrence Livermore National Lab: LLNL has developed tiny capsules (about0.1 mm across) 

made of gas-permeable plastic and containing C02 solvents. When placed in seawater, they 

rapidly draw C02 from the brine into the microcapsules. When these are taken from seawater 

and/or heated, they release the absorbed C02. 

Arizona State Univ: This is a gas-permable membrane (sheet or spiral-wound) that operates with 

a small pressure gradient. It can dissolve C02 into brines (e.g., to feed algae) or draw C02 from 

them. 

• X (formerly Google X, part of Alphabet): The core technology is a desalination reverse-osmosis 

membrane which separates brine from water as well as C02. Originally, it was explored as part 

of the "seafuels" project, also known as Foghorn. The goal was to create fuels from the ocean at 

competitive prices. The tech has not yet moved to that price, so the project was shelved. 

• Naval Research Lab: The NRL was looking at ways to extract Co2 from sea water as feedstocks 

to jet fuels while ocean bound. The core technology is alkalinity swing - they create acids by 

making protons electrolytically, which leads both to bicarbonate/ carbonate production and 

hydrogen generation). 

*Note: This does not include approaches such as ocean iron fertilization or ocean liming, which do 

not directly draw C02 from seawater and involve adding materials ta the ocean. 

Today, there are no formal federal programs that support separation of C02 from the ocean. This limits 

what is possible in terms of commercial co-investment and small business support, and limits the rate 

and variety of innovation. 

C02 Pipelines 

5. At the hearing, witnesses agreed that a major hurdle for CCUS projects is capital 

financing and upfront costs. It was also discussed that C02 pipeline infrastructure buildout is needed to facilitate the transport of COz for reuse and to improve the financing of 

projects. 

a. What specific federal policies would facilitate the construction of COz pipelines? 
55 


27318.044

A number of policies could facilitate C02 pipeline construction. The key issue is up-front capital cost, so 

any facilitating policy must manage that risk directly. 

First, the creation of a substantial "production tax credit" for C02 storage (like the FUTURE Act) would 

provide enough financial incentive for pipeline developers to take construction capital risks. Other kinds 

of tax provisions, such as a large refundable lTC for pipeline construction or private activity bonds, would 

help. Second, grants to developers would suffice- these could be given through new programs at the 

DOE, Dept. of Transportation, ar as block-grants to states. Third, creating new C02 utilities would 

provide new authorities for utility commissions to gather rate-payer funds to finance pipelines, much as 

some natural gas pipelines are financed today. 

b. Is it true that a majority of new pipelines could be built within existing interstate 

pipeline corridors? Or will C02 pipeline infrastructure build-out occur in areas 

that will require extensive NEP A requirements? 

It is highly likely that the majority of new pipelines would attempt construction within existing pipeline 

corridors and rights of way. This is for permitting and logistical simplicity. However, some very good sites 

are not along existing pathways, and would face risks in aggregating land rights and fairways. In some 

cases, Federal funds would be involved, and may require NEPA regardless. 
56 

Senator BARRASSO. Well, thank you to all three of you for your 

very interesting testimony. We will have some time for members to 

ask questions now, so I appreciate your willingness to participate 

in this. 

I am proud to say, Mr. Fry, that our home State of Wyoming is 

already a leading promoter of CO2 pipeline development, with the 

Wyoming Pipeline Corridor Initiative that you outlined. This proposes developing a network of CO2 pipelines connecting oil fields 

with CO2 sources, both manmade and natural, within Wyoming. 

In my opening statement, I showed a chart that showed many 

areas across the Country that could benefit from similar efforts. 

Are there things that the Federal Government could do? We just 

heard from Dr. Friedmann, who I thought eloquently talked about 

some of the problems that were out there. Are there things, Mr. 

Fry, that you think we could do to make it easier for other States 

to replicate what you are doing in Wyoming? 

Mr. FRY. Well, thank you, Mr. Chairman. Yes, I believe there 

are. As Dr. Friedmann mentioned, the opportunity to move forward 

with 45Q legislation provides that financial incentive that we are 

looking at. But as far as a regulatory incentive, the discussion that 

I made in regards to up-front planning is probably key in this instance, so if States outside of Wyoming took the initiative to focus 

on where they could capture the CO2 and where they could inject 

it, be it either in EOR fields or in saline formations, I think they 

could be ahead of the curve substantially. 

Senator BARRASSO. And your testimony mentions that CCUS provides us with the opportunity to treat carbon dioxide as a valuable 

commodity when it is used in conjunction with the enhanced oil recoveries you just mentioned. Do you think that the use of CO2 for 

enhanced oil recovery is a more powerful incentive to develop 

projects like this and decrease CO2 emission, compared to, say, extensive more regulations on the energy industry? 

Mr. FRY. Yes, sir, I believe it is. It seems like project proponents 

typically are more open to letting the market drive something like 

this than they are being dictated by regulations. So I agree 100 

percent that is the way to go. 

Senator BARRASSO. Mr. Greeson, can you explain some of the 

benefits of retrofitting plants with CCUS to produce cleaner energy? And what can CCUS provide that other clean energy technologies such as wind and solar can’t? 

Mr. GREESON. Sure, thank you, Chairman Barrasso. The benefits 

of retrofit are that is where the bulk of the emissions that everybody is trying to address is coming from now. It is not new plants, 

because there are very few new coal plants being proposed or developed, at least in the U.S. It is possible to do carbon capture on a 

greenfield plant, and do it even less expensively than you could on 

a retrofit, but the bulk of the emissions we are trying to address 

these days are on retrofitted opportunities. And then with the design that we ended up with, and thanks to the difficulties of navigating New Source Review, we ended up with a stand-alone cogeneration facility to supply steam and electricity to the cogen, to the 

carbon capture. 

Our plant actually increased the number of clean megawatt 

hours being produced at this plant, rather than using some of the 

57 

load at the plant for parasitic loads. So, yes, it definitely improves 

the emissions profile. The coal plant that we have attached our carbon capture system to has the same carbon footprint as a gas-fired 

combined cycle. 

Senator BARRASSO. Mr. Fry, could you elaborate on some of the 

specific obstacles that the National Environmental Policy Act, or 

NEPA, presents when companies try to build CO2 pipelines? 

Mr. FRY. I think the greatest challenges it presents would be 

time constraints, as well as financial constraints when a company 

comes in to develop a project that may take them 10 years to finalize their NEPA document, at which point the market could have 

changed drastically and they may no longer have an economically 

viable project. So time is a big concern. 

Senator BARRASSO. As you mentioned with time being a big concern, what are some improvements that could be made to preserve 

the goals of NEPA and facilitate quicker development of the pipelines? 

Mr. FRY. From my perspective, if people would follow the model 

that we are laying down in Wyoming as far as up-front planning, 

so they can build that strong foundation, they would have a lot less 

constraints to challenge their project and the future of their NEPA 

analysis. 

Senator BARRASSO. And then, Mr. Greeson, my final question, 

you stated that there are certain regulatory requirements that dissuade companies from installing the CCUS technology. Can you explain how New Source Review, which is required by the Clean Air 

Act, actually dissuades companies from installing technology that 

would decrease emissions in certain areas? 

Mr. GREESON. Certainly. So, many of the retrofit opportunities 

are in plants that are old and depreciated, and there are certain 

triggers under the Clean Air Act that would trigger a New Source 

Review, including the size of the investment that you are about to 

make versus the book value of the host unit. So many of these 

units are already very well depreciated and so an investment the 

size of $1 billion, per se, would trigger a New Source Review, and 

that is, as I mentioned in my testimony, pretty risky for the host 

coal unit. So it makes it a very gut-wrenching decision to make to 

go that way. 

Senator BARRASSO. Thank you. 

Senator CARPER. 

Senator CARPER. Let me just ask my dear Democratic colleagues. 

Anybody in a hurry to go to another hearing or something you need 

to rush off to? If you do, I will yield my time to you initially. Anybody? 

I have no questions. 

[Laughter.] 

Senator CARPER. No, actually, I do. 

Julio Friedmann, that is an interesting combination of names. 

How did you get to be a Julio? 

Mr. FRIEDMANN. I was a birthday present, sir. 

Senator CARPER. OK. Thank you. 

[Laughter.] 

Senator CARPER. Whatever. 

58 

Mr. FRIEDMANN. My mom is Columbian, my father is Venezuelan, and they met in the Catskills in Grossinger’s Hotel. 

Senator CARPER. Well, that would explain it. 

[Laughter.] 

Senator CARPER. More people should meet there. 

I want to give you just a moment to respond to the claims made 

by one or two of our other witnesses that we need to make changes 

in environmental regulations in order to grow the use of this technology, which we all seem to support. I believe, as I have said, 

there are real benefits to CCUS. I also believe that we need to deploy it in a manner that doesn’t create additional environmental 

problems while solving carbon dioxide emissions. 

In your opinion, are the biggest hurdles holding back the use of 

this technology are they financial in nature or do they deal more 

with environmental permitting? 

Mr. FRIEDMANN. It has been my experience and is strongly my 

opinion that the primary barriers are financing barriers. It is not 

possible to get a loan to build a CCS plant because you can’t get 

your money back. And it is not possible to get an equity investor 

for a CCS plant because you can’t get your money back. If we had 

clean energy portfolio standards, instead of renewable portfolio 

standards, it would be possible to get rate recovery for utilities. We 

do not have access to those mechanisms. 

If there was something like 45Q, where you could have sufficiently large investment and production tax credits, that would be 

enough to close the financing gap. The regulatory issues would be 

the next thing that people would look at, but the first thing they 

would look at, like Mr. Greeson said, is the up-front capital cost 

and the financing. 

Senator CARPER. You were very straightforward, but just tell us 

what do we need to do? Just say it again. I want us to listen. What 

do we need to do in order to provide for a more level playing field 

for this technology? 

Mr. FRIEDMANN. Fundamentally, we want to close the financing 

gap. So, today, if you wanted to retrofit a plant, like the NRG Petra 

Nova guys have done, you need to raise capital, you need to discount that capital over some period of time. You have to have a finance raise; you need an internal rate of return. If you can’t get 

the IRR, you can’t get the project. So you need to close that financing gap. 

Depending on how you calculate it, the production tax credit for 

wind today is about $60 a ton for CO2 abatement. That would be 

large enough. The amounts of money that have been proposed for 

45Q would be enough to launch a whole bunch of projects in the 

industrial sector and in the power sector for gas, as well as coal. 

You just need to close that financing gap. 

Senator CARPER. I just want to say very briefly, Mr. Fry, Mr. 

Greeson, do you approve this message? 

Mr. GREESON. I largely approve whatever Julio says. 

Senator CARPER. OK, thank you. 

Mr. Fry. 

Mr. FRY. I agree the financing gap is a huge challenge, and afterwards we could certainly work on expediting the environmental 

issues. 

59 

Senator CARPER. All right. 

Mr. Friedmann, Julio Friedmann, ever since President Trump 

announced that the U.S. would exit from the Paris agreements, I 

have been concerned that America will cede, as I said in my opening statement, cede opportunities to lead the world in technological 

innovation that could both fight climate change and create manufacturing jobs right here in the USA. Do you share my concerns? 

And would you further discuss the policies that you believe the 

U.S. should pursue to bridge the financial gaps with the CCUS, unless you think you have already done that? You may have done 

that in answer to my last question. 

Mr. FRIEDMANN. In response to your question, the fundamental 

fact of the Paris Agreement is 197 countries have agreed that carbon matters. That means there is no market anywhere in the world 

where carbon is not an issue. There is no market anywhere in the 

world where carbon is not an issue. That creates opportunities for 

U.S. technology export. In fact, today the United States is an unambiguous global leader in carbon capture, utilization, and storage. 

If we do not continue to press for an innovation agenda, if we do 

not continue to deploy plants, we will lose that advantage to other 

countries that are making substantial investments along these 

lines, notably, China, Japan, and Germany, and Canada. 

Senator CARPER. And Canada? 

Mr. FRIEDMANN. Canada is actually, is in fact the technology 

that is deployed on the smaller version of David Greeson’s plant up 

at Boundary Dam, that is Canadian technology, Cansolv, and the 

largest saline aquifer storage project in the world today is up in 

Canada as well, it is the Shell Quest Project. 

Senator CARPER. OK, thanks. 

Mr. Greeson, you testified that NRG’s Petra Nova’s project was 

on budget and on time with the current environmental protections 

in place. Is that correct, yes or no? Is that correct? 

Mr. GREESON. Yes, our project was on time and on budget, yes. 

Senator CARPER. Good. Thanks. In your written testimony you 

mention this project started in 2009 because NRG felt that we 

would have Federal regulations in place that would constrain carbon emissions from power plants. If you would, just answer briefly. 

Do you believe that NRG would make the same decisions today, 

based on this Administration’s policies to roll back all regulations 

dealing with climate change and carbon pollution? 

Mr. GREESON. So, we are hearing from our customers. We are a 

competitive retail electric provider. We sell everything we sell 

under competitive market structures. We do not have rate base to 

put off cost onto, so everything we do we do because we are trying 

to make our product more attractive to our customers. 

Right now, our customers are asking for lower carbon products, 

and so the current status of the Administration almost doesn’t matter. We looked at what our customers are demanding, and that is 

what we try to provide. 

Senator CARPER. Do you believe that NRG would make the same 

decisions today based on this Administration’s policies? 

Mr. GREESON. So—— 

Senator CARPER. If you would just say yes or no, then we will 

go on. 

60 

Mr. GREESON. So the question—there are so many factors that 

go into making the decision. Definitely, the Administration’s position would be one of those factors that we would consider. 

Senator CARPER. All right, thanks. 

Thanks very much. 

Senator BARRASSO. Thank you, Senator Carper. 

Senator INHOFE. Senator INHOFE. Thank you. Thank you, Mr. Chairman. You 

know, this is kind of interesting because there are so many areas 

here where we are in agreement. That isn’t always true in this 

Committee. 

Now, you folks are all experts in these areas and, of course, we 

are not up here, but we are going to be wanting to make decisions, 

wanting to make changes so that we can accomplish some of the 

goals that we are talking about. So essentially, we are talking 

about three steps: first, the captured technology separates some 

CO2 from gases produced in electricity generation; second, purified, 

compressed, and all of that; and, finally, the CO2 is injected into 

underground reservoir for use in other purposes. 

Now, as the Chairman pointed out in his opening remarks, this 

does have great opportunities, opportunities that you have talked 

about in your testimony, Mr. Greeson. But there also is the problem of NRS. I was chairman of this Committee at the time that we 

went through this and, yes, it is ironic that was set up in order to 

make things come out cleaner, and it didn’t work out that way. 

Now, when you are looking at opportunities you have, we need 

to start talking about a legislative fix that we can do. We can do 

it maybe through NRS; we can do it a number of different ways. 

I know you outlined a few things, but have you gone into a lot of 

detail on this as to what we at this side of the table could do to 

resolve the problem that we are here meeting on today and to enhance our production? 

Mr. GREESON. Thank you, Senator. I did not go into detail in my 

testimony. We can certainly provide more detail. 

Senator INHOFE. I think you referred to your written testimony. 

Did you get more detail there? 

Mr. GREESON. There is a little more detail there talking about 

the steps that can be taken to make the NSR process less of a deterrent to a major capital improvement in environmental performance, yes. 

Senator INHOFE. Right. Now, you had several operations. You 

only used this in one area. What was the reason for that? Why 

were you able to face the risks that were posed by NSR in that one 

area and not the rest of some of your other operations? 

Mr. GREESON. So, the design of this carbon capture system, it 

only touches the host coal unit right before the exhaust stream 

goes up the chimney. So, because of that, the carbon capture system itself was not considered an addition to the host coal unit; it 

has a separate air permit for the carbon capture system. So, in that 

way we did not have to face NSR on the host coal unit. 

Senator INHOFE. I see. All right. Well, you know, in my State of 

Oklahoma we are doing this right now. It is Chaparral. I have been 

to their operations. One is in the northeastern part of the State 

and one in the northwestern part of the State. 

61 

Have you ever thought about what kind of a figure we would be 

looking at if we resolved that problem and were able to utilize this 

enhanced system? 

Mr. GREESON. So, every project and every plant is different. I can tell you for our project that we probably could have spent $50 million less if we had been able to take steam from the host coal unit. 

Senator INHOFE. That is interesting. How are things in Houston 

right now? 

Mr. GREESON. Drying out. 

Senator INHOFE. Yes. Well, that is good. That is good. 

Mr. GREESON. Drying out. We are getting there. 

Senator INHOFE. Mr. Fry, you know, we are interested in doing 

the same things that you have been doing. Do you have any specific 

advice for us to accomplish the successes that you have achieved 

in Wyoming? 

Mr. FRY. I would suggest that if you all have opportunities to 

find CO2 sources and places to inject it, whether it be EOR, saline, 

start planning now. Look at where you could route pipelines with 

the minimal amount of constraints. And I realize that you have a 

different Federal land status than we do in Wyoming, but I think 

you would follow those same steps to plan ahead and make your 

process a lot easier. 

Senator INHOFE. Thank you. That is very helpful. 

Thank you, Mr. Chairman. 

Senator BARRASSO. Thank you very much. 

Senator WHITEHOUSE. Senator WHITEHOUSE. Thank you, Chairman. First, let me thank 

you and Senator Capito for cosponsoring the bill that is kind of at 

the heart of today’s hearing. I would hope that other colleagues on 

the Committee would look at it and consider cosponsoring it as 

well. We are up to 25 cosponsors, which is a terrific number, but 

it is certainly not enough to convince the majority leader that he 

can get over a 60-vote threshold. So to the extent that I don’t want 

to run too many more Democrats onto it because I don’t want to 

get too far out of balance, to the extent that we can get more Republican cosponsors, I think that could move the project forward. 

I also want to say that I have been to Saskatchewan Boundary 

Dam and I have been to Shenandoah, Iowa, where they are growing algae with the waste exhaust from ethanol plants, so I have 

seen this technology in action; I know that it is tangible and real. 

And everywhere I have gone I have also been told what Dr. 

Friedmann and Mr. Greeson have told us, which is that it is really 

hard to find a revenue stream to pay for the sequestered or captured carbon. 

I want to emphasize Mr. Greeson’s testimony that enhanced oil 

recovery was and is still today the only known way to create a revenue stream that could offset the cost of building and operating 

carbon capture right now. That is how Saskatchewan works. It is 

near an oil field, so you can do EOR. But there is an enormous 

amount of capacity out there and capability and technology to do 

this that isn’t going to be located near an oil field, and at this point 

that is being shackled, smothered by this problem. 

One of the things that we are seeing emerging is recognition of 

a cost of carbon, which implies that there should either be a payVerDate Aug 31 2005 13:29 Nov 07, 2017 Jkt 000000 PO 00000 Frm 00065 Fmt 6633 Sfmt 6633 S:\_EPW\DOCS\27318.TXT VERN
62 

ment for reductions in carbon emissions or a price on carbon emissions. And, Mr. Greeson, you mentioned that absent a price on carbon emissions, this is a problem, so presumably a price on carbon 

emissions would help create a revenue stream. Is that correct? 

Mr. GREESON. That is correct, sir. 

Senator WHITEHOUSE. It would facilitate market and industry 

getting together and trying to come up with ways to take advantage of that price on carbon emissions, correct? 

Mr. GREESON. That is correct. Any opportunity to create a revenue stream is going to help. 

Senator WHITEHOUSE. And, Mr. Friedmann, the heart of your 

testimony about the different ways that government, through specialized government programs, can help, isn’t it true that the fundamental problem here is that there is no way to be compensated 

for reducing carbon, presently, without either a price on carbon or 

a benefit for carbon emission reductions? Correct? 

Mr. FRIEDMANN. Correct. 

Senator WHITEHOUSE. So, you know, one thing that is interesting 

to me is that if you get away from Congress, into courts and into 

administrative agencies, which are forums in which facts tend to 

have to be factual and economics tend to have to be real and false 

and misleading statements tend to be punished, you see a really 

strong and, in fact, inevitable move toward a social cost of carbon. 

Three circuit courts of appeal, everyone that have looked at the 

question, have either approved or required administrative agencies 

to adopt a social cost of carbon. District courts, over and over, have 

approved or required a social cost of carbon repeatedly. Mining expansions have been stopped because the applications did not include a social cost of carbon. FERC has been instructed to consider 

a social cost of carbon in pipeline hearings. 

The National Highway Transportation Safety Administration has 

been instructed to use a social cost of carbon and told that it cannot be zero. The Department of Energy was affirmed in considering 

a social cost of carbon with respect to commercial refrigeration. Indeed, the court said, yes, that kind of has to happen. New York, 

Minnesota, and Colorado public utility or public service commissions have adopted social cost of carbon. The Illinois State legislature has adopted the social cost of carbon. 

It is now a commonplace for U.S. corporations and for major investors to bake an internal social cost of carbon into their decisions. 

Mr. Friedmann, do you think that is a sensible move on the part 

of these courts, these administrative agencies, and these corporations? 

Mr. FRIEDMANN. It is simply a market reality. They are trying 

to manage the carbon risks and how the market values those carbon risks. Every multinational oil company that I know of carries 

a social cost of carbon and an operational cost of carbon for their 

investment planning, and they won’t build a unit unless it can 

have a strong internal rate of return given a high cost of carbon. 

Senator WHITEHOUSE. So, I would suggest if it is good enough for 

the oil industry itself, it might, at some point before too long, be 

good enough for Congress to consider. 

Mr. Chairman, I would love, if it works, to have a second round 

to ask Mr. Friedmann a particular question. We have dealt mostly 

63 

with atmospheric CO2 with technologies that relate to extracting 

the CO2 load from our oceans, which are dramatically acidifying as 

a result of the CO2 load. 

Senator BARRASSO. Certainly. 

Senator ROUNDS. 

Senator ROUNDS. Thank you, Mr. Chairman. 

Mr. Fry, I would like to begin with you. First of all, the Wyoming 

pipeline corridor takes a significant step forward streamlining the 

NEPA process for pipeline infrastructure. How do you envision the 

Wyoming process becoming integrated in an overly complicated and 

complex Federal process, and how do you see the Wyoming process 

perhaps serving as a model for the Federal system? 

Mr. FRY. Sir, our expectation is that we will develop this project 

and work through the Federal agencies with a final product of an 

environmental impact statement. And after we are completed with 

that, companies could come in and build within this corridor system at a reduced environmental analysis that would probably be an 

environmental analysis. So we are hoping to cover the bulk of the 

EIS and the environmental impacts, and then they would come in 

just to do a lesser analysis, as well as their surveys for specific resources. 

Senator ROUNDS. OK. 

Mr. Greeson, you indicated that the biggest challenge you have 

is the original or the capital costs involved in creating the projects 

up front. At the same time, you also indicated that, as I understand it, with regards to the costs, you specifically pointed out the 

fact that the NSR, the current process in place really placed a burden on the company who was trying to capture the carbon. It made 

it more difficult because in doing so the existing rules would perhaps have included an additional cost to upgrade an existing plant, 

which the vast majority of the plants in the United States are older 

plants. Fair enough? 

Mr. GREESON. Fair enough. 

Senator ROUNDS. So it made it more difficult for you to actually 

take advantage of an opportunity here to capture carbon in the way 

that your company analyzed that process. 

Mr. GREESON. Yes, Senator. 

Senator ROUNDS. OK. 

Mr. Friedmann, would you agree that the approach that Mr. 

Greeson has expressed and the concern that his company clearly 

looked at with regard to the NSR in its current format could be improved upon? Or at least in your analysis or as you have looked 

at this, would it be fair to say that if there was a way to take these 

older plants and to allow them to be able to be integrated into 

some sort of a CCUS process, that there would be a value there to 

taking a second look at the current rules in place at the Federal 

level to allow more certainty as to what their costs would be to upgrade that plant? 

Mr. FRIEDMANN. I am in no way, shape, or form an expert on 

New Source Review and regulatory issues associated with it. What 

I feel comfortable saying is that I have heard the same concerns 

that Mr. Greeson has expressed by many other power producers, 

that they are considering projects and would like to do projects, but 

64 

they are concerned about the potential triggering of New Source 

Review and how it will affect the project process. 

Senator ROUNDS. Thank you. 

I think as we look at this from differing points of view, there is 

a discussion about the social cost of carbon, which is a discussion 

as to if there is a desire to reduce the total amount of carbon within the atmosphere that is being released, there are two ways to approach it. No. 1, you can simply say, well, we are going to add a 

cost to anybody who creates carbon within the atmosphere or, No. 

2, we can look at, as has been suggested here, that there are positive attributes that we can take that carbon and use it for a positive way in which to actually add additional power or additional resources to our energy portfolio. 

It seems to me that there is more logic in not increasing the cost 

of energy by adding a social cost of carbon to the creation of energy, 

but, rather, looking at, in particular, this particular process that 

you all are discussing today, CCUS, in particular with being able 

to produce more energy at this time. 

It would appear that there is a suggestion that there is a divergency here, and I guess I am just curious. It seems to me that we 

ought to be focusing on how we create more using the existing resources we have, rather than simply saying let’s add a cost to the 

cost for the consumer in the first place up front. 

It looks to me, Mr. Greeson, like your company has tried to address this by saying let’s take this carbon and make it a value or 

give it a value, as opposed to calling it a cost. Would you care to 

comment on the difference between the two approaches? 

Mr. GREESON. Well, Senator, clearly, because we are a competitive electric retail company, raising cost is not an option for us because others would simply undercut us and get the business. So, 

as I mentioned in my testimony, we found a way, using enhanced 

oil recovery coupled with carbon capture, to not increase the cost 

of electricity, and yet we are reducing by 1.6 million tons a year 

the emissions from the host power plant. So we kind of were able 

to run the circuit and get everybody something in this project. 

Senator ROUNDS. My time has expired, but at the same time 

what you are saying is if we were to take a look at the NSR rules 

in place today, there may very well be other companies out there 

who might very well be able to accomplish the same thing if there 

was certainty, so that they knew that if they did upgrade an existing facility to take advantage of CCUS, that we might very well be 

able to capture more carbon and do it in an efficient manner and 

actually add value, as opposed to costing those consumers more 

money. 

Mr. GREESON. Yes, I would agree. If you can solve the biggest 

problem, which is the up-front capital, then you have to attack the 

next reasons why people wouldn’t adopt this technology, and NSR 

would be one of those reasons. 

Senator ROUNDS. Thank you. 

Thank you, Mr. Chairman. 

Senator BARRASSO. Thank you, Senator Rounds. 

Senator HARRIS. Thank you. 

65 

Dr. Friedmann, thank you for your work at Lawrence Livermore. 

It is certainly a jewel of California and, dare I say, the Nation, so 

thank you for your work there. 

Some would say that a price on carbon via cap and trade or a 

carbon tax, or any other mechanism, would help, but that ultimately wind and solar are often cheaper than CCS and have fewer 

smog-forming pollutants and other impacts to communities. What 

would be your perspective on that, in terms of that being one of the 

reasons why CCUS needs subsidies? 

Mr. FRIEDMANN. I would have three specific responses to that. 

First of all, what you said is only true in some markets; it is not 

universally true. Across the United States, resources vary in terms 

of solar and wind. The costs of power vary dramatically. So what 

may work well in one State or one region is not actually universally true, and that is also true internationally. 

The second thing I would say is that a straight levelized cost of 

electricity basis, which has its own flaws, it does not include the 

cost of transmission buildout and it doesn’t include resilience and 

all these other sorts of things, just on that basis alone CCS is cost 

competitive with a boatload of clean energy technologies, including 

offshore wind, including rooftop and residential solar in a bunch of 

markets. 

What is not possible, though, is to finance those projects. Those 

other projects actually can recoup through a renewable portfolio 

standard or through the investment or production tax credit, they 

can recoup the capital investments. I know of at least three companies that scrubbed really hard looking to see if they could finance 

a CCS project, and they said, nope, we are going to do solar, wind, 

and gas, because that is what we can do today. 

The third thing that I would say is that I simply don’t think of 

this at all as an either-or question. We absolutely need more solar 

and wind. I don’t think that is debated. In fact, the supports and 

subsidies which we have put in place to enable those technologies 

have created new industries, supported jobs, made America a technology leader, all that stuff. 

We are still not reducing our emissions anywhere near quickly 

enough. We are far, we are far, far away from a satisfactory trajectory. And if you actually look at the emissions gap report from the 

United Nations, we are not even on the current policy trajectory for 

2010; we are on the baseline worst business as usual scenario. We 

are emitting 53 billion tons of greenhouse gas emissions every year. 

So I simply think that we need to do more. We need an innovation agenda; we need a deployment agenda. And, in fact, CCS is 

required as part of the mix, along with efficiency, along with nuclear, along with solar, along with wind, along with electric vehicles, along with biofuels. We actually need all of the above. 

Senator HARRIS. So you make a very persuasive point. Why, 

then, do you believe have we not developed financial incentives and 

investment in this method? 

Mr. FRIEDMANN. I think there are two issues which come back. 

The first is that the financing for CCS projects is lumpy. David has 

had to live through this. At some point or another, someone has to 

write a billion dollar check, and that makes it hard to pull the financing together. You can actually deploy much smaller wind and 

66 

solar projects without taking the same financing risk. And that has 

created, among other things, a distributed energy renaissance in 

this Country that has its own benefits associated with it. You can’t 

really do that with CCS; you need the large central application. In 

fact, that is its primary use and benefit. 

The second is one that I grapple with all the time. Everyone 

knows what a windmill is. Everyone knows what a solar panel is. 

Everybody knows what a gas turbine and a nuclear plant is. It is 

very, very hard to communicate what CCS is to people. And so 

even for people who care about this topic, even people who are enthusiastic about climate change, there is an educational and informational barrier that comes with it. 

There are other reasons as well. I am happy to talk to you offline 

and give you a much wider description. 

Senator HARRIS. That would be helpful, if we are going to pursue 

anything as a Committee. It would be good to predict the obstacles. 

Tell me, in your work in this area, have you done an analysis? 

You have mentioned, but have you done an analysis of what we 

would look at in terms of, if there were such an investment, what 

it would do in terms of job creation for the Country? 

Mr. FRIEDMANN. Actually, I worked with Dan Kammen on this 

a number of years ago in which we looked at the job creation associated with it. I don’t have the numbers now, I am happy to followup with you, but it is substantial. 

There are two dimensions to this that I think are also important. 

One of them is it is not just job creation, which is real, but it is 

also job sustainment. This is particularly important to the unions, 

which are looking at a number of their jobs going away associated 

with the industry. But the other is actually because you are dealing 

with these large centralized facilities, you don’t just create jobs or 

sustain jobs, you actually create and sustain communities; that 

whole communities that are at risk actually get sustained through 

CCS. 

Senator HARRIS. Can you give me just a couple of examples of 

the sustainable jobs that this would create? What type of job are 

we talking about? 

Mr. FRIEDMANN. Any number of things. Let’s just do quickly, 

anybody building and operating the plant. I think there is well over 

1,000 jobs associated with the Petra Nova project and there are 54 

or some number of full-time employees who are working on that 

site. They are high-paying jobs; they are good jobs. GE has stopped 

doing research on CCS because they didn’t see a market opportunity, but they were looking at an export technology market as 

large as their wind export technology market that is thousands and 

thousands of jobs. 

You are talking about boilermakers, heavy equipment manufacturers, and all of the equipment that comes with that; the people 

who make compressors, the people who make pipelines, the people 

who make control systems, and, of course, all of the people who 

support those people. 

Senator HARRIS. Thank you. 

Thank you. 

Senator BARRASSO. Thank you, Senator Harris. 

Senator ERNST. 

67 

Senator ERNST. Thank you, and thank you to our witnesses for 

being here today. 

Like many of my colleagues here on the Committee, I believe 

that an all-of-the-above energy approach is the most effective way 

to create jobs, promote energy independence, and ensure that our 

households and businesses have reliable and affordable electricity. 

Perhaps no State is better in leading the way or setting an example 

of this approach than Iowa, my home State. Largely a result of our 

State policies and community engagement, I am proud to say that 

Iowa now has one of the Nation’s most diverse energy mixes, with 

wind now providing nearly 40 percent of our electricity. 

And to give you an idea of how quickly this diversification has 

taken place, in 2008, 76 percent of our electricity came from coal; 

and just recently, 2016, now about 47 percent of our electricity 

comes from coal. And I would encourage other States to look to 

Iowa as an example of the successful application of an all-of-theabove energy approach. 

Dr. Friedmann, in your testimony, you touched on biomass being 

a possible application for carbon capture, utilization, and sequestration. Iowa’s energy plan, which was unveiled by our Governor, 

Kim Reynolds, earlier this year identifies one of our State 

strengths as its abundant and largely untapped biomass potential, 

which could be used to produce biofuels or generate electricity. And 

by 2030 it is projected that Iowa will lead the Nation in crop residues and manure, over 30 million metric tons, which have the potential to be used for bioenergy. 

Companies are starting to invest in cellulosic technology in Iowa, 

such as POET’s Project Liberty, near Emmetsburg. And now with 

DuPont’s plant near Nevada, we can boast of being home to the 

largest cellulosic ethanol facility in the world. 

Dr. Friedmann, can you elaborate on the potential for this type 

of biomass as an application for CCUS? 

Mr. FRIEDMANN. Thank you, I am happy to. One of the first applications for CCUS is actually directly in the ethanol industry. 

Ethanol fermentation creates a byproduct stream of pure CO2 . The 

Decatur project in Illinois is happily storing about a million tons 

of carbon dioxide every year into a deep saline formation, and has 

been doing so successfully. It is worth noting that for companies 

who are able to do this, they could actually cash in on that in the 

California low carbon fuel standard market, which actually has a 

metric and a methodology in which the carbon footprint for those 

fuels is assessed and includes carbon capture and storage. So, in 

fact, if those fuels were sold into the California market and CCS 

was applied to them, they would be benefited today at the cost of 

about $90 a ton they would be compensated for that. 

Senator ERNST. And we would love to sell those fuels to California. 

Mr. FRIEDMANN. I am happy to talk about that more. 

Second, as you mentioned corn stover and crop residues, there is 

an opportunity for co-firing of biomass with coal plants. This is 

something which is relatively straightforward to do. It is hard to 

get large volumes in that, but in fact you can reduce the carbon 

footprint with that. If that plant is a CCS plant, you begin to trend 

into something that is called BECCS, bioenergy with CCS, which 

68 

is one of the many technology pathways to get carbon removal or 

negative emissions. Essentially, the corn pulls the CO2 from the air 

and then you put the CO2 underground. 

The Intergovernmental Panel on Climate Change and many 

other groups have insisted that BECCS is necessary for us to hit 

their climate target and, in fact, Iowa and the Midwest are excellent places to test such things. 

The third thing is to think about enhanced terrestrial uptake. 

This is looking at things like soil carbon and increasing the richness in there. There is a meme going around right now of soil carbon farmers, and these guys actually have difficult access to the 

carbon market but are actually able to increase their yields. Our 

laboratory is actually working with Iowa State University on a 

project to in fact do exactly that, and look at ways to enhance terrestrial uptake. 

There are other ways to go about this as well, but functionally, 

for example adding biochar, which is a byproduct of fast pyrolysis; 

and there are ways to think about combining char and char gasification with coal firing. There are many, many ways to think about 

combining biomass with CCS in a way that can achieve deep 

decarbonization. 

Senator ERNST. I appreciate that very much. And it is fascinating 

and technology that I hope we are able to tap into and use in the 

very near future. 

With that, my time has expired. Thank you very much, Mr. 

Chair. 

Senator BARRASSO. Thank you, Senator Ernst. 

Senator DUCKWORTH. Senator DUCKWORTH. Thank you, Mr. Chairman, and thank you 

for convening this very important hearing. 

Like many of my colleagues, I also support the FUTURE Act, 

which will provide industry with incentives they need for widespread implementation. I am a proud sponsor of CCUS because I 

have seen firsthand how effective this technology can be in bringing economic and environmental benefits. Decatur, Illinois, in my 

home State, is home to Archer Daniels Midland, a project that 

began capturing carbon dioxide from an ethanol production facility 

in April 2017. This project can capture up to 1.1 million tons of 

CO2 per year, which is sequestered in a nearby deep saline rock 

formation. 

So from power plants to industrial facilities to oil operations, 

there is obviously tremendous opportunities to deploy CCUS, and 

I believe we must invest and prioritize CCUS so that we can maintain our leadership in the energy sector, as well as realize its tremendous job growth potential. 

Dr. Friedmann, can you please share the economic development 

potential associated with wide-scale implementation of CCUS not 

just here in the U.S., but also for us to sell or deploy this technology abroad as well? 

Mr. FRIEDMANN. Thank you. It is clear to me that there are large 

opportunities for deploying CCS in the United States and in the 

North America market, including Canada and Mexico, which are 

seriously chasing CCS and looking for projects and partners. The 

market opportunity and the job opportunities in that are very 

69 

large. I have seen a number of commercial estimates that suggest 

that by 2025 this could be a $6 billion market in the United States 

with the appropriate policy structures. 

I think, however, the big opportunity is the international market. 

I have had the good fortune of representing our Country in negotiations and discussions with China, with India, with Japan, with 

Australia, with South Africa, and with many countries in Europe. 

They are aware that they are not going to hit their climate targets 

without CCS either. They are a bit reluctant to take it on up front, 

a bit the way that my children are reluctant to clean their room, 

but ultimately my children have to clean their room and these 

countries know that they have to do that work as well. 

Right now it is still the case that the United States can develop 

and lead the world in deploying and marshaling that technology, 

and that is an export opportunity that is immense; many hundreds 

of billions and trillions of dollars of total revenues. 

Senator DUCKWORTH. And so if we don’t invest in its development here in the U.S., are other countries poised to take over 

should we not develop and be the ones to provide the CCS technology abroad with this market potential? If we don’t do it, is somebody else going to step in and provide the service? 

Mr. FRIEDMANN. Unquestionably, and a number of countries are 

very aggressive on that front. The most obvious is Norway. Since 

1993, Norway has had a carbon tax. They are the global leaders 

in carbon capture technology. They have the technology center, 

Mongstad, which they are using to test technologies from around 

the world, and they have their own state-sponsored research programs and commercialization programs to get that technology out. 

Aker Clean Carbon and Statoil are in fact actively competing in 

this space. 

Next in line I had mentioned Canada, and that is an important 

actor, but probably the one to keep an eye on, not surprisingly, as 

always, is China. Japan has put a lot of money into this, and, in 

fact, Dr. Greeson’s plant is in fact using this Japanese technology, 

because that was the market beater at the time. But China is 

dumping an awful lot of money into center of excellence on everything from geological storage to material science to supercomputing, and they are fielding large projects and demonstration now 

for the first time ever. 

XI Jinping is clearly making commitments to accelerate their 

current commitments beyond the Paris commitment, and CCS is 

one of the things that they can do. They are able to lay out tariffs, 

declare projects, marshal thousands of engineers at the drop of a 

hat, and are very much looking at this technology space for the 

global lead position. 

Senator DUCKWORTH. So they have clarity in their national policy 

in investing in this technology. And I am not one to support red 

tape for the sake of red tape, but I think that with CCS I think 

there is a different challenge for businesses here in the U.S. that 

want to make these investments. I think we fail to send a direct 

signal to business indicating that we take the threat of climate 

change seriously, and with that we don’t have a clarity in our national energy policy that would set up the goals, the support, so if 

70 

we don’t have a national policy the way the Chinese do, then people are going to be reluctant to get into the industry. 

Mr. FRIEDMANN. If we are going to be competitive in that race, 

we have to run faster. And the way that you get the team to run 

faster is to incent them. And there are many, many different ways 

to do that, but you need to send that signal and you need to make 

it big enough so that companies will commit the capital and the 

staff and the human beings and all the rest of it to really make 

it work. 

Senator DUCKWORTH. Thank you. I am out of time. 

Thank you, Mr. Chairman. 

Senator BARRASSO. Thank you, Senator Duckworth. 

Senator CAPITO. 

Senator CAPITO. Thank you, Mr. Chairman, and thank all of you 

here. Appreciate it. I would like to give a shout out to the ranking 

member on my subcommittee, Senator Whitehouse. We are both on 

the 45Q tax credit bill, the FUTURE Act, and my colleague from 

Illinois a cosponsor as well. 

Dr. Friedmann, when you were questioned by the Senator from 

California as to the job benefits of pursuing an active CCSU or 

CCUS format around the Country, one of the jobs that you didn’t 

mention, but I am sure you knew, were the coal mining jobs that 

are associated with keeping coal as an active energy source here 

in the Country. So, for a place like West Virginia, that has great 

meaning, so I will add that to the mix of the numerous jobs that 

you mentioned would be not just created, but sustained through an 

active CCUS commitment. 

Let me ask you just a quick question, Dr. Friedmann. In your 

statement you mentioned, and you mentioned this orally, too, that 

there is 16 projects that are currently doing this and 22 that are 

going to be doing it by the year 2020. We know Petra Nova is one 

in the United States. How many of these 16 are located in the 

United States? 

Mr. FRIEDMANN. Quite a number of them. The LaBarge project 

in Wyoming is one of these projects. The Air Products project in 

Port Arthur, Texas, actually the largest clean hydrogen project in 

the world, is in the United States. Plant Barry, the Enid Fertilizer 

Plant that actually sends the CO2 through the company of Chaparral into Oklahoma for enhanced oil recovery. There is quite a lot. 

Senator CAPITO. OK. Good. I was wondering, since you mentioned that a third in North America, I thought was that a way of 

saying North America, but not in this Country. But that is not the 

case, so thank you for that. 

Mr. Greeson, you mentioned some of the regulatory burdens. We 

have talked a lot about the financial burdens, and that is part of 

the reason that 45Q, the FUTURE Act, is so important, I think. In 

terms of the regulatory burden, is there any way that you can approximate which one is a bigger burden to you, or was to you at 

Petra Nova, in the development? Was it the financial, was it the 

regulatory, or are they all just too melded in there together to really make a distinction? 

Mr. GREESON. Thank you, Senator. Absolutely far and away the 

up-front capital cost was the biggest barrier. We found a number 

of like-minded companies that joined in with us, so we limited each 

71 

company’s exposure to the project. So that is how we were able to 

raise the capital. 

But behind that, we did have to do a lot tap dancing to find a 

way to make this project work. One was to just have a minimal 

touchpoint on the existing plant so that we avoided New Source 

Review. But there were others. As I mentioned, the Class VI versus 

Class II injection well dust-up. That was real exciting at a time we 

were very near the end of our financing and the lenders were asking, what are you talking about an extra $100 million dollars? 

NEPA was also something that was, we feel like, a burden on the 

project with no real environmental benefit. Every aspect of this 

project is on disturbed lands, industrial sites, so we weren’t really 

incrementally having any impact, but yet, because of the grant, we 

had to go through that. So there were a number of things like that. 

Senator CAPITO. Right. Well, thank you. 

Mr. Fry, I noticed in your bio that you acquired your beginning 

education at Davis & Elkins College in West Virginia, so very 

proud of that. 

Mr. FRY. Yes, ma’am. 

Senator CAPITO. Are you a West Virginian or a Wyomian? 

Mr. FRY. I am originally from Virginia. 

Senator CAPITO. Well, that is OK. 

[Laughter.] 

Senator CAPITO. In any event, talking about pipelines, we are 

having issues in West Virginia, I am sure all across the Country, 

obviously, about siting and permitting of pipelines. From a technological standpoint, is there a way to convert old pipelines into pipelines that can carry carbon, or do you have to have a specialized 

new pipeline developed, or is that a bad concept, to use an old pipeline for what is considered to be a newer technology? 

Mr. FRY. So, actually, to utilize an old pipeline would be a challenge because the CO2 is in supercritical State, which means it is 

under extremely high pressure. But what we have done in siting 

our pipeline corridors in Wyoming is followed alongside of those old 

pipelines, whereby we disturb less ground by following to the side 

in a safe manner. So there is an opportunity to use the pipeline in 

the corridor, but not the pipe itself. 

Senator CAPITO. Is the corridor, as I understand it, just intraState, so you are not crossing over into other States? 

Mr. FRY. Yes, ma’am. It is challenging from a NEVA perspective 

to do internal, but when we started to think about coordinating 

with our neighboring States, where we would enter and leave the 

State, it just became too much of a challenge. So we come close to 

the borders, but we are not promoting going across. 

Senator CAPITO. Do you consider this like a step one for you? Because I would imagine, in order to really maximize the financial 

benefit, being able to go outside of the State would probably be 

beneficial as well. 

Mr. FRY. We are hoping that our model follows through in our 

neighboring States, then we can start opening those discussions. 

Senator CAPITO. Thank you. 

Mr. FRY. Thank you. 

Senator BARRASSO. Thank you, Senator Capito. 

Senator Whitehouse, you had some additional questions? 

72 

Senator WHITEHOUSE. Thank you, Chairman, I appreciate the 

courtesy. 

I gave Dr. Friedmann a warning of where I would be going. We 

have been talking in this hearing virtually exclusive of atmospheric 

carbon; and obviously that is a significant problem. For as long as 

humankind has been on our planet, we have had atmospheric carbon dioxide concentrations between about 160 and 300 parts per 

million. We have now blown through 400, which humankind has 

never experienced; and projections are that we will crest above 500 

parts per million. 

So, I don’t mean to deprecate the importance of atmospheric carbon dioxide hyper-concentrations, but 30 percent of that carbon dioxide has been absorbed, roughly has been absorbed chemically 

into the oceans, with a very, very predictable, replicable scientific 

chemical result, which is that the oceans acidify. 

Mr. Chairman, I actually had a moment in the wee hours of the 

morning during one of our late sessions to perform I think the first 

scientific experiment ever done on the Senate floor, blowing my 

CO2 -laden breath into the glass of water that the pages give us 

on the Senate floor with pH dye in it and showing that, in fact, just 

that dramatically increased the acidity of the water in the glass. 

So this is something that any middle school science lab could replicate, and not very debatable. 

So we really need to, I think, focus a little bit on the oceans here 

as well, and if you could just say a few words about what you see 

as potential carbon load reduction technologies and prospects in 

our oceans. And do you agree or disagree with any of what I just 

said? 

Mr. FRY. I 100 percent agree with everything that you just said. 

Ocean acidification is an often overlooked consequence of global 

greenhouse gas emissions and, in fact, atmospheric carbon dioxide 

becomes ocean carbon dioxide with negative consequences. It is already an economic burden for a number of fisheries. In particular, 

oyster fisheries around the Country are already adding lime to the 

waters because the oysters aren’t growing fast enough because of 

the consequences of ocean acidification. 

In the same way that we now face such an urgent problem that 

people have begun to think about pulling carbon dioxide directly 

out of the air, I was pleased to not only be part of, but to discover 

there are a large number of groups that are now looking at pulling 

carbon dioxide directly out of the oceans; it is called direct ocean 

capture. 

I can identify eight different groups and companies who have developed technologies to do such things, including work that is going 

on at the National Laboratories. So, again, some work that was executed at Lawrence Livermore to pull carbon dioxide directly out 

of oceans. 

This has a number of positive consequences. For me, the first 

order one is in fact that you reduce ocean acidification at its source. 

Rather than adding more stuff to the ocean, we are subtracting the 

problem in the first place, and that is an unambiguous benefit. 

Second is the fact that when you pull carbon dioxide out of seawater, you actually create new things. Most importantly, you precipitate carbonate minerals that are commonly used in building 

73 

materials. Sand, aggregate, cement, additives, all these things can 

actually be made by pulling carbon dioxide out of the ocean. And 

the costs for that today are substantive but, again, the best time 

to plant a tree is 20 years ago; the second best time is now. If we 

get on the stick with an innovation agenda, we can think about 

how to develop better technologies and ratchet down the costs for 

those kinds of operations. 

Senator WHITEHOUSE. And these ocean technologies suffer from 

the same finance problems that the atmospheric technologies do, 

which is that, presently, there is no revenue stream that rewards 

the reduction of carbon dioxide levels in the ocean in the same way 

that, other than EOR, there is no revenue stream that rewards reduction of carbon dioxide levels in the atmosphere. 

Mr. FRY. That is correct. Even the revenues from byproducts for 

things like the lime materials are nowhere near enough to close the 

financing gap. So projects are not being fielded and the amount of 

research that is being done on this topic is very small. 

Senator WHITEHOUSE. Who knew hard to get investors for something where there is no prospect of a revenue stream? Thank you. 

Senator BARRASSO. Well, thank you very much, Senator 

Whitehouse. 

Thank you all for your responses. 

Senator Gillibrand, whenever you are ready. 

Senator GILLIBRAND. Thank you, Mr. Chairman and Mr. Ranking 

Member. 

This hearing on carbon capture technology comes at a time when 

parts of our Country are seeing the devastating consequences of climate change caused by carbon emissions. My heart breaks for the 

people in Florida, Texas, Puerto Rico, Virgin Islands, Caribbean 

who are literally struggling to put the pieces of their lives back together following both Hurricane Harvey and Irma. 

But as we help them to rebuild, we must also confront the reality 

of climate change. We cannot ignore that carbon emissions are 

causing our ocean temperatures to get warmer, which is fueling 

more powerful hurricanes. Reducing carbon emissions should be an 

urgent priority for this Committee, and now is exactly the time we 

should be talking about it. 

I would also note that this is the second hearing this Committee 

has held on carbon capture technology. While this is an important 

topic that deserves our attention, I hope that we will also hold 

hearings on what we can do to facilitate the development of renewable technologies like wind and solar. 

This Country used to be at the forefront of wind and solar technology; we invested in it. But because we haven’t invested in it, a 

lot of the manufacturing has gone to China, our biggest competitor. 

And when you manufacture something, you are better poised to do 

next generation innovation. So we are losing a competitive space to 

China right now, and that has to be regained. 

So if you truly believe that we should have an all-of-the-above 

energy strategy, then we should be talking about renewable energies as well. I have two questions for our witness Dr. Friedmann. 

Dr. Friedmann, in your testimony you State the barriers to carbon capture technology are not fundamentally technical or regulatory. Could you speak more to what you mean by that? 

74 

Mr. FRIEDMANN. Carbon capture technology was first invented in 

1930 and fielded in 1938. This is actually a relatively mature technology even at scale. It is used in many, many commercial operating facilities. 

Carbon storage was first deployed in 1972 for the purpose of enhanced oil recovery in the Permian Basin of Texas. We have been 

injecting large volumes of carbon dioxide underground basically for 

45 years. 

These technologies are separately mature. Combined, we have 

been doing carbon capture and storage projects around the world 

for over 20 years. And, in fact, we have many projects that are operating above a million tons of year, so some of the geotechnical 

questions that people had concerns about have fundamentally been 

resolved. 

The regulatory issues are not the primary barrier either. There 

are, I think, questions that people have about what is the appropriate degree of oversight for such things, but fundamentally, if you 

are going to be doing this, the gross scientific and technical consensus is you have to monitor. You have to monitor the carbon dioxide that is stored. And, in fact, that is one of the things that 

Hilcorp is doing at the Petra Nova project. That technology also exists, is well demonstrated, and there are dozens of companies to 

sell it. 

So the primary issue is finance. You have to get a lot of money 

up front; you have to get a rate of return. Absent incentives that 

can close the gap for that, like we have provided for other clean energy technologies, we are not going to see deployment, we are not 

going to have a market. 

Senator GILLIBRAND. Storage of sequestered carbon requires 

large areas, which you mentioned, often deep underground or in 

the ocean. There are legitimate questions around the challenges of 

identifying suitable carbon reservoirs for storage and ensuring that 

any potential impacts on water supplies or other disturbances to 

the environment are addressed before a project is constructed. 

Is there any reason why carbon capture projects should be subjected to different environmental review standards or processes 

other than other energy projects? 

Mr. FRIEDMANN. As I had said, the whole purpose of doing carbon capture and storage is in order to demonstrate the CO2 is staying out of the atmosphere. That is the primary undertaking. So, in 

fact, there is some obligation to verify and validate that the carbon 

dioxide is remaining underground and that there are no demonstrable substantive public harm that comes from it. 

It is my strong scientific opinion that the risks associated with 

geological storage are grossly overblown. In fact, any good storage 

site is going to be a good storage site. The Earth is in fact spectacularly well configured to store carbon dioxide indefinitely. But it is 

incumbent on operators to ensure that the carbon dioxide is in fact 

not reentering the atmosphere, and that requires an additional 

monitoring protocol. 

Senator GILLIBRAND. Thank you, Mr. Chairman. 

Senator BARRASSO. Thank you very much. 

Senator CARPER. 

75 

Senator CARPER. Thanks, Mr. Chairman. I want to ask, for the 

record, to enter a report from a new organization called Global CO2

Initiative, which is chaired by a Delawarean, a fellow named Bernard David. And he is doing some, I think, really interesting work 

that is relevant to what we are talking about here today. 

Senator BARRASSO. Without objection. 

[The referenced information follows:] 

76 


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Available online at www.sclencedirectcom 

Energy 

SciVerse ScienceDirect Procedia 

ELSEVIER Energy Proccdia 37 {201 :n 6R54- 0866 

GHGT-11 

C02 Utilization from "Next Generation" C02 Enhanced Oil 

Recovery Technology 

Vello A. Kuuskraaa*, Michael L. Godec•, Phil Dipietrob 

Abstract 

C02-cnhanccd oil recovery (C02-EOR) has emerged as a major option fOr productively utilizing C02 emissions 

captured from electric power and other industrial plants. Not only can oil fields provide secure. weii characterized 

sites l()r storing C02• they can also provide revenues to offset the costs of capturing CO;;. Though utilization of 

captured C02 emissions for enhanced oil recovery has hcen uodc1way for some time. further advances in C01-EOR 

tcchnoklgy could significantly improve the technology's applicability as a rewnue generator for CO~ capture and a 

large-scale C01 storage option. With application of ''next generation'· C02-EOR technologies in geologically 

favorable settings, the volume of C02 stored could exceed the C02 content of the oil produced. The paper draws 

significantly on the recently completed report sponson~d by the U.S. Department of Energy, National Energy 

Technology Laboratory (U.S. DOE/NETL) and prepared by Advanced Resources International entitled. '"Improving 

Domestic Energy Security and Lowering C02 Emissions with .. Next Generation·· C01MEOR'·. 

The paper introdw.:es the feasibility of applying "next generation" C02-EOR technologies to new, challenging areas. 

such as to residual oil lones (ROZs) below and beyond the structural confinement of existing oil fields and to 

offshore oil fields. The paper provides a case study that tracks the performance and the economics of COrEOR in 

the Permian Basin of West Texas. While much or the infonnation in the paper is dra\\Tl from the COrEOR 

experiences in North American oil fields. the paper also examines the C02 utilization and storage potential from 

applying ''next generation" C02-EOR technology to the large oil ticlds of the world, drawing on extensions of work 

performed by Advanced Resources International for the I EA Greenhouse Gas R&D Programme. 

The paper concludes with two key messages. First, with application of"next generation" technologies to a broader 

set of oil resources, the market f()f utilinltion of C02 for enhanced oil recovery is much larger than previously 

assumed. Second. the revenues from the sale of captured C02 emissions. along with research that reduces the costs 

of C02 capture, can greatly <lccderatc the time when CCS (nO\·V CCUS) can be applied at wide scale. 

re 2013 The Authors. Published by Elsevier Ltd. 

Selection and/or pccr-rcvkw under responsibility ofGifG']' 

Keywords: C'O:>·EOR: CO~: enhanced oil recovery; CCUS; residual oil zones; ROZ; oil fields; CO" capture 

* Corresponding author. Tel.: + 703-528-8420; fax:+ 703-528-0439. 

h'-mail address: vkuuskraa~_ijadv-res.com. 

1876--6102 4J 2013 The Authors. Published bv Elsevier Ltd. 

Selection and/or pceHcvicw under responsibility of 01 KiT 

doi: !O.l0JO!j.cg:ypro.20! 3.06.61 R 
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Vello A Kuuskraa el al. I Energy Pm('edia 37 (2013) 6854- 6866 

l. Introduction 

Four key questions are at the heart of gaining wide-scale acceptance for using C02 enhanced oil 

recovery (C02-EOR) as a major carbon management strategy; namely: (l) what is the size of the prize?; 

(2) could CO,-EOR, like wind and solar, provide essentially net zero carbon energy?; (3) how much of the 

C02 used for EOR will remain securely stored?; and (4) to what extent could CO,-EOR provide a marketdriven option for C02 capture? 

/./. The Size C!(the Pri;e 

Typically, only about a one-third of the original oil in-place in a conventional oil field is recovered 

with traditional primary and secondary methods. In the U.S., this leaves behind a massive, nearly 400 

billion barrel target for "next generation" C02-EOR in existing oil fields, plus an additional 140 billion 

barrels in residual oil zones (ROZ) below and beyond existing oil fields, Figure I. Worldwide, our 

estimate is that the "left behind" oil resource is many times larger, in excess of 5,000 billion barrels. 

Application of C02 enhanced oil recovery (CO,-EOR) provides the economically most favorable means 

for recovering a significant portion of this "left behind" oil and for storing massive volumes of C02 

captured from industrial and electric power plants. 

• In the U.S., the "size of the oil prize" for "next generation" C02-EOR technology is I 00 billion barrels 

of economically recoverable oil, assuming an oil price of$85 per barrel,' a C02 price of$40 per 

metric ton, and a return on investment hurdle of 20%, Table 1.1.2 

• The economic C02 demand to recover I 00 billion barrels of oil with CO,-EOR is 33 billion metric 

tons, Table I.'·' With natural C02 sources estimated at less than 3 billion metric tons, this means that 

the "size of the C02 utilization and storage prize" in the U.S. is 30 billion metric tons. This is equal to 

35 years of C02 emissions captured from 140 GWs of coal-fired power.3 

1.2. Carbon Neutral Oil 

At a typical ratio of 1 metric ton of C02 injected and stored for every 2.5 barrels of oil recovered, the 

carbon balance of oil produced with CO,-EOR is essentially neutral, when using C02 that would 

otherwise have been vented to the atmosphere. Under special conditions, such as gravity stable C02 

flooding, the C02-EOR process can store considerably more C02 than the carbon content of the oil, 

Figure 2. 

Today, a significant number of activities are underway that find and bring more oil to the surface, 

including exploration and drilling for conventional oil. These arc activities that provide no offsets to the 

carbon in the produced oil. Yet, no rational official, one concerned with a country's economic wellbeing, its energy security, and its jobs, has called tor a stop to oil exploration (except in environmentally 

fragile areas) as long as it is done in a safe and environmentally sound way. ln addition, recently 

Norway's Statoil announced that it has adopted a goal of achieving 60% recovery efficiency from its 

offshore oil fields, without use of C02 injection. We are not aware of any Norwegian public officials that 

condemned Statoil's pursuit of efficiency and conservation of the nation's oil resources.' 

tin this report, all economic value numbers are expressed in U.S. dollars. 

6855 
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Vcl!o A. KtuHkraa eta!./ tllergy Proccdw 37 (2013) 6854 ~ 6866 

1.3. A Closed-Loop System 

The operation of a CO,-EOR project is essentially a closed-loop system, Figure 3. Initially, about half 

ofthe injected C02 is trapped or dissolved in the reservoir and its fluids. The C02 that is produced with 

the oil is recycled (separated and re-injected back into the reservoir), with an increasing portion of thereinjected C02 trapped. At the end of a C02 flood, essentially all of the purchased C02 is stored in the 

reservoir when the operator closes the field at pressure. 

1.4. Providing Revenuesji>r C02 Capture 

Finally, CO,-EOR provides a market and revenues for the C02 captured from industrial and electric 

power plants. In the U.S. alone, we estimate that the CO,-EOR industry could provide revenues of$1.2 

trillion for C02 capture and delivery from fossil fuel power plants and industrial facilities. ln addition, 

with "next generation" technology, the CO,-EOR sector, over the course of thitty to forty years, would 

generate domestic economic activity equal to $8.5 trillion in the U.S. alone, Tahle 2. As important, 30 

billion metric tons of anthropogenic C02 that would have otherwise been vented to the atmosphere would 

be pennanently stored. 

2. Status of C02-EOR 

CO,-based enhanced oil recovery, using state-of-the-art (SOA) technology, is already being 

implemented in the U.S., particularly in the oil fields of the Permian Basin of West Texas, the Gulf Coast 

and the Rockies. 

• C02-EOR currently provides about 284,000 barrels of oil per day in the U.S., equal to 6% of U.S. 

crude oil production, Figure 4. 5 C02-EOR has been underway for several decades, starting initially in 

the Permian Basin and expanding to 123 C02-EOR projects currently installed in numerous regions of 

the country, Figure 5. 

• In 2010, a total of62 million metric tons of C02 was supplied to EOR operations in the U.S., Table 3. 

Approximately 20% (13 million metric tons) ofthis C02 came from industrial sources, natural gas 

processing plants, and hydrocarbon conversion f.1cilities (e.g., coal gasification). By 2020, 

approximately 14 Mt of additional C02 supply will become available from large-scale integrated 

CCUS projects in the U.S. Department of Energy's (DOE) portfolio.' 

• A robust network of pipelines exist in the Permian Basin that transports this C02 from natural C02 

deposits and gas processing plants to the Denver City Hub, Figure 5. In addition, numerous new C02 

pipelines have recently been placed on-line to deliver CO, to Gulf Coast and Rocky Mountain oil 

fields 5 · 

6 These include Denbury·s 320 mile Green Pipeline along the Gulf Coast, Occidental 

Petroleum's new $850 million Century natural gas/C02 processing plant and pipeline facilities in West 

Texas, and Denbury·s GreenCore C02 pipeline linking the Lost Cabin gas processing plant and other 

C02 sources in Wyoming to Rocky Mountain oil fields, Figure 5. 

3. Overview of"Next Generation" CO,-EOR Technologies 

Realizing the full benefits of utilizing C02 as part of a CCUS strategy requires having access to "Next 

Generation" CO,-EOR technology. Before proceeding further, it is useful to address the questions --just 
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Vl"!lo A Kuuskraa et al. I EnenF Proadia 37 (2013) 6f\54- 6866 

what constitutes ''Next Generation" C02 enhanced oil recovery and how does it diller from the CO,-EOR 

technology in use today~ Briefly stated, "Next Generation" CO,-EOR incorporates four significant 

changes in technology and industrial practices: 

• First are a series of scientifically-based advances in currently practiced miscible and near-miscible 

CO,-EOR technology, including: 

Improved sweep efficiency and mobility control (reservoir conformance), 

Advanced technology of reservoir surveillance (monitoring and process control), 

More efficient contact and production of the reservoir's remaining mobile (and immobile) oil, 

Lowering the threshold minimum miscibility pressure (MMP) for shallower, heavier oil 

reservoirs, and 

Significantly increasing the volumes of C02 injected and efficiently used. 

• Second is integrating C02 capture from advanced coal- and natural gas-fired electric power plants, oil 

refineries, hydrogen plants and coal-to-liquids (CTL) facilities with C02 utilization by C02-EOR, 

• Third is application ofCO,-EOR to residual oil zones (ROZs), and 

• Fourth is deployment of CO,-EOR in o1Tshore oil fields. 

3. 1. Integrating C02 Capture and Utilization with COrEOR 

To a large extent, operators of integrated gasification combined cycle (lGCC) tacilities, proposed CTL 

plants and other carbon conversion projects have already "voted with their teet" by turning to oil fields 

for storing C02• Three such projects are: 

• Southern Company's Kemper County lGCC plant, which plans to provide 1.1 to 1.5 MMt/yr to 

Denbury Resources for CO,-EOR in oil fields in Louisiana and Mississippi. Integrating C02 capture 

and utilization involved formulating innovative contractual terms and alternative options for C02 

delivery6 

• Summit Energy's Texas Clean Energy IGCC project, which plans to sell 3 MMt/yr for CO,-EOR from 

the Permian Basin of West Texas in competition with natural sources of C02

6 

• The "poster child" for integrating large-scale C02-EOR with CCS is the capture of 150 MMcfd 

(-3MMmt/yr) of C02 from the Northern Great Plains Gasification plant in Beulah, North Dakota and 

its transportation, via a 200 mile cross-border C02 pipeline, to two CO,-EOR projects at the Weyburn 

oil field in Saskatchewan, Canada, Figure 6. 7 

3.2. Residual Oil Zone ("ROZ") 

No discussion of "next generation" technology would be complete without a discussion of the major 

volumes of oil that exist and can be recovered with CO,-EOR from the residual oil zone (ROZ). Residual 

oil zones exist in the lower portions of oil reservoirs that have been hydro-dynamically swept by the 

6857 
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6R5R Ve!lo A. Kuuskraa ~:t a!_ I Energy Procediu 37 (2013) 6!154- 6806 

movement of water over a time period of millions of years. One may label this movement of water and 

its displacement of oil as "nature's waterflood". Because the "lett behind" oil in the ROZ is at or near 

residual oil saturation, C02-EOR is required to re-mobilize and recover this oil. 

Work by Advanced Resources and Melzer Consulting has identified 42 billion barrels of oil in-place 

below existing oil fields in three U.S. basins-- Permian, Big Horn and Williston. '·'· 10 Importantly, recent 

work by Melzer Consulting for the Research Partnership to Secure Energy for America (RPSEA) shows 

that the ROZ resource also occurs beyond the outlines of existing oil fields and exists as a series of 

areally extensive ''ROZ fairways", Figure 7. Melzer Consulting and Advanced Resources estimate that 

about 100 billion barrels of oil in-place exists in the ROZ ·'fairways" of the Permian Basin alone. Based 

on preliminary modeling, we estimate there is 27 billion barrels of economically recoverable oil from the 

ROZ (below oil fields and from the ROZ "fairway''). The "C02 utilization and storage prize" offered by 

the ROZ resource is !3 billion metric tons, Table 1. 

The viability of recovering oil from ROZs is already being demonstrated by a series of ROZ field 

projects - - at Seminole oil tield by Hess, at Wasson Denver Unit by Occidental, and at Goldsmith oil 

field by Legado, among others. An imp01tant R&D goal for the U.S. (and the world) is establishing 

optimally efficient oil recovery and C02 storage in ROZs using miscible CO,-EOR. 

3.3. CO,-EOR in OjJvhore Oil Fields 

The deep, light oils common to Gulf of Mexico (GOM) offshore oil fields are amenable to miscible 

C02-EOR technology. With the continued discovery of oil fields in the deep waters of the Outer 

Continental Shelf (OCS), the size of this resource target continues to grow. However, the deployment of 

C02-EOR technology in offshore oil fields faces many challenges, including limited platform space for 

C02 recycling equipment, the expense of drilling new C02 injection wells, and the need to transport C02 

from onshore sources to offshore platforms. While these barriers and challenges can be addressed with 

advances in technology, they add substantial costs to the oil recovery process. C02-EOR projects have 

been undertaken in a small handful of offshore oil fields in shallow GOM waters; however, currently 

none are operating. As such, the fourth "next generation" COrEOR application involves undertaking the 

challenge of deploying innovative designs and advanced CO,-EOR technology in offshore oil tields. 

4. International C02-EOR and C02 Storage 

In 20 !1, Advanced Resources prepared for the International Energy Agency Greenhouse Gas R&D 

Programme (JEAGHG) an assessment of worldwide C02 storage and oil recovery potential offered by 

C02-EOR. The C02 supplies for EOR were assumed to be primarily from power plants, cement plants 

and refineries with large-scale C02 pipelines transporting the C02 to geologically favorable oil fields. 

The study assessed 54 large world oil basins for C02-based enhanced oil recovery, using two 

complementary methodologies . 

11 

• High-level, first-order assessment of C02-EOR and associated storage potential, using U.S. experience 

as the analog. 

• Calibration of the above tirst-order basin-level estimates with detailed modeling of 47large oil fields 

in 6 basins. 
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Vcllo A. Kuuskraa et al, I Enf!rg,,. Procedia 37 (20!3) 6854- 6R66 

The study established that the "size of international oil and C02 utilization (and storage) price" from 

applying CO,-EOR to already discovered oil fields is about 1,300 barrels of incremental oil recovery and 

370 billion metric tons of C02, Table 4, This is equivalent to utilization (and storage) of captured C02 

from about 2,000 GWs of coal-fired power for 35 years, Much of this demand can be met by large, 

existing anthropogenic C02 sources within distances of 800 kilometers (500 miles) of these oil basins, 

New anthropogenic sources, such as the large oil refineries and hydrogen plants being constructed in the 

Middle East and the high C02 content natural gas fields in the Far East, provide major opportunities for 

utilization of C02 by CO,-EOR, 

5. Permian Basin CO,-EOR Case Study 

The purpose of the Permian Basin CO,-EOR case study is to provide the reader basic information by 

which to address the question: ''What does a successful C02-EOR project look like?" 

C02 injection into the Denver Unit of the giant Wasson (San Andres) oil tield began in 1985, helping 

arrest the steep drop in oil production, Before the start of CO,-EOR, oil production had declined Jrom 

about 90,000 BID to 40,000 BID and was on pace to decline to below 1,000 BID in the next 20 years, 

After the initiation of the CO, flood, oil production increased to about 50,000 BID, Today, twenty four 

years after the start of the flood, the Denver Unit still produces at 30,000 BID, Figure 8, 

At the completion of the C02 flood, Oxy expects the Denver Unit to recover nearly two-thirds of the 

approximately 2 billion barrels of original oil in-place, with C02-EOR providing nearly 20% oil recovery 

efficiency (400 million barrels) on top of already high oil recovery efficiency from primary methods and 

the waterflood, In turn, the Denver Unit C02 flood will utilize over 100 million metric tons ofC02,

6 

A broader look at Pcrn1ian Basin C02-EOR projects shows that the C02 tlood at the Wasson (Denver 

Unit) oil field, while exemplary, is not unique, Using an oil price of $100 per barrel, Occidental 

Petroleum, the largest C02-EOR operator in the Pennian Basin, expects its CO,-EOR projects to provide 

a net cash margin (before corporate taxes) of$56 per barrel, after subtraction of royalties, operating costs, 

C02 purchase and amortized capital, Figure 9, C02 purchase (plus recycling operations) constitutes the 

largest single cost item in the C02 flood. Even with delay between investment of capital and the 

production of oil, the EOR case study and the results from the other C02-EOR projects in the Penn ian 

Basin show that an economically favorable market exists for anthropogenic C02, 

6. Summary 

The information set forth in this paper argues that C02 enhanced oil recovery deserves to be a major 

part of a worldwide carbon management strategy, The "size of the prize" is large, the oil produced is net 

carbon energy, the injected C02 will remain stored securely, and C02-EOR can provide a market-driven 

option for accelerating C02 capture. 

Acknowledgements 

This study was sponsored by the U,S, Department of Energy, National Energy Technology 

Laboratory, under Contract No. DE-FE000400L 
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6~60 Veflo A. Kuutkrrw e! ai. I Energy Procedia 37 (2013) 6854 -- 6866 

Table I. Impact of Applying ·Next Generation'" C0 ~EOR Technology to U.S. Oil Fields and ROZ '·Fairways" 

Resource Aren 

More efficient recovery from ''lower 48'' oil fields 

Alaska/offshore 

Residual oi!Jonc (below oil fields) 

Residual oil zone '·fairways'' (preliminary) 

Total 

Economic Oil 

Recovery (BBbls)* 

60 

13 

20 

tOO 

Demand for C02 

(Billion Metric Tons) 

17 

33 

*,\t ~85 f}er barrel and $40 per metn~ ton, COz m<ir!..et pnte w1th 20 "·0 1ate nlr~tum (bef<:>r~ tax) 

Somce Adl'an<:~d Resonrc~' lntemationJ!, Inc {201 J) 

l'ahlc 2. The ''Value Chain' of '·Next Generation" CO~~EOR (U.S. Only) 

Revenue Recipient Value Chain Function Revenues Pet· TOTAL' 

Barrel($) (S billion) 

Power/Industrial Companies Sak of C02** $13.20 $1,320 

Federal/State Treasuries Severance/Income '!'axes $19.80 $1.980 

U.S. Economy Services. Materials and Sales $26.50 $2,650 

Other Private Mineral Rights $7.70 $770 

Oil Industry Return of! on Capital $17.80 $1,780 

Total $85.00 $8,500 

Table 3. Significant Volumes of Anthropogenic CCh art! Already Being: Injected for EOR 

Location of 

Oil Fields 

Texas, New Mexico. 

Oklahoma, Utah 

Colorado, Wyoming 

Mississippi 

Michigan 

Oklahoma 

Saskatdle\van 

TOTAL (Million rfd) 

'I'OTAL (Million ml'tric 

Location of 

C02 Sources 

Geologic {CO, NM) and Gas 

Processing, Fertilizer Plant (TX) 

Gas Processing (Wyoming) 

Geologic (Mississippi} 

Gas Processing (tv1ichigan) 

Fertilizer Plant (Oklahoma) 

Coal Gasification (North 

Dakota) 

Geologic 

1.600 

930 

2,530 

49 

CO, Supply 

Anthropogenic 

190 

300 

10 

35 

150 

685 

13 

!0'(~1cfper m~tnc ton) 
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Veflo ;\. Kttuskraa et al. I f:.'nergy PnH'ediu 37 (2013) 6854-6866 

Table 4. Technical Oil Recovery and C02 Storage Potential from the Major Oil Basins ofthc World Using from "Next 

Generation"* COrEOR Technology 

Region CO,-EOR Oil Recovery C02 Storage Capacity 

(llillion Barrels) (Billion :\1ctric Tons) 

I. Asia Pacific 47 13 

2, C. & S. America 93 27 

3, Europe 41 12 

4 FSU 232 66 

5, M. EastiN. Africa 595 !7(1 

6. NNOther 38 ll 

7. NNU.S. !77 51 

8, S. Africa/Antarctica 74 21 

TOTAL 1,297 370 

Fig. l. Large Volumes Of Domestic Oil Remain ''Stranded" Afier Traditional Recovery Operations 

Original Oil In-Place: 6illl8 Barm!s 

"Stranded" Oil In-Place: 396 B Bamls 

6861 
84 


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Ve!!o A. Kuuskraa eta!. I Energ_r Procedia J7 ( 2013) 61<54 - 6866 

Fig. 2. Integrating CO,-EOR and C02 Storage Could Increase C02 Storage Potential 

Fig. 3. C02-EOR Technology: A Closed-loop System 
85 


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Vello A. f.:twskraa e! ai. Proccdin37 (20/3) 6854" 6Nb6 

Fig. 4. Domestic Oil Pmduction ti·om COc-EOR 
86 


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6864 Vello A. Kuuskm(l et af. I En('lxr Procedia 37 (20/3) 6854-6866 

Fig. 6. "Pos!er Child'' for Integrating COr LOR and CO:: Storage 

Fig. 7. Map of Pcmlian llnsin ROZ Fairways. 
87 


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w 

0 

"' "' 

V£1/o KwLYkrao ct of./ Ene1xy Jlroredit1 .37 (2013'; 685"- ~· 6866 

Fig. l·L C02-EOR at Denwr Unit, \A:rL;;son Oil Field. 

Fig. 9 Permian Basin C02-FOR PR\jt'~t Cost Structure 

Tu 
88 


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Vello !L Kuuskraa et aLI Energy Pr()(.Wlia 37 (2013) 6/<,54- 6866 

References 

1 Advanced R~sources International, Inc. (ARI). Improving Domestic Energy Security and Lowering C()z Emissions with '·Nexl 

Generation'" C01wEnhanced Oil Recovery (201 1 ), www.netl.doe.gov/energy-analyses/pubs/storing%20co2%20w%20eor_ 

final.pdt: 1 1\dvanccd Resources lntcmationaL ''Using C02 Enhanced Oil Recovery to Aced crate the Implementation of Carbon Capture and 

Storage··. presentation to ARPA-E, U.S. Department of Energy, Washington, D.C., Octobcr201l 

~DiPietro, P., J., P. Balash, M. Wallace .. A Note on Sources of C02 Supply for Enhanced-Oil-Recovery Operations. Society of 

Petwleum Engineering. Economics & Management (/\pri12012). 

~ "'Statoil Targets 60% Average Oil Recovery Rate", WW\\'.rigzonc.corn. August 29,2012. 

'Oil and Gas Journal Survey. J\pril2010. 4 Various industry presentations and publications 7 Whittaker, S. IEA GHG Weybum-Midale C02 Storage & Monitoring Project Presentation at the Rt:gional Carbon Sequestration 

Partnerships Annual Review (October 5. 201 0), W\VW.netLdoc.gov/publications/proceedings/1 0/rcsp/presentations/ 

Tues%~20am/Karen%20Cohen/Whittakcr.%,20WMP _RcgionaJ0/<.>20Partncrship.pdf 8 'Technical Oil Recovery Potential from Residual Oil Zones: Pennian Basin", prepared by Advanced Resources International, Inc. 

for thl": ll.S. Department of Energy. Onicc of Fossil Energy. Oflicc of Oil and Natural Oas, October 2005. 

s ·''!'echnical Oil Recovery Potential from Residual Oil Zones: Big Horn Basin''. prepared by Advanced Resources lnternationa!. 

Inc. for the U.S, Department ol' Energy, Office of Fossil Energy, Office of Oil and Natural Gas, February 2006. 1

o ''Technical Oil Recovery Potential !Tom Residual Oil Znnes: Williston Basin"', prepared by Advanced Resources International, 

Inc. for the U.S. Department of Energy, Office of Fossil Energy, Office of Oil and Natural Gas, February 2006. 11 "CO~ Storage ln Depleted Oilfields: Global Application Criteria For Carbon Dioxide Enhanced Oil Recov~ry··. lEA GIJG 

Programme Technical Report Number 2009~12, December by Adv<mced Resources International. Inc. 
89 

Senator CARPER. Thank you. And built on some points made by 

Sheldon Whitehouse of all people. 

Senator WHITEHOUSE. Astonishing. 

Senator CARPER. And a word, if I could, about the Global CO2

Initiative. It is focused on research and development, commercialization of products that reuse carbon dioxide. In other words, 

this Initiative is trying to find new ways to make the CO2 captured 

from our coal plants valuable in the marketplace. 

The roadmap for this is called the Roadmap for the Global Implementation of Carbon Utilization Technologies, and I encourage anyone interested in today’s hearing to also take some time to look at 

the report and the work that they are doing. And we thank Bernard David and the folks that are working with him. 

Thanks, Mr. Chairman. 

This question has been asked a couple times now, but I am going 

to ask it once more. Repetition is good, as you know. 

How important is carbon capture and sequestration technology 

for the coal industry and for assisting the U.S. in meeting our global climate goals? And, economically, how big of an opportunity are 

we missing if we don’t capitalize on this technology? 

You responded to this in waves, but I want you to do it again. 

Mr. FRIEDMANN. Because of the way that you framed the question, I have the opportunity to do exactly that. In 2007, MIT released something called The Future of Coal Report. I had the good 

fortune of working with—— 

Senator CARPER. In 2007? 

Mr. FRIEDMANN. In 2007. 

Senator CARPER. Ernie Moniz. 

Mr. FRIEDMANN. Ernie Moniz—— 

Senator CARPER. He actually was a witness at a field hearing 

that I held there. 

Mr. FRIEDMANN. Yes. 

Senator CARPER. On this report. 

Mr. FRIEDMANN. And one of the findings—— 

Senator CARPER. And his hair was cut just the same then as it 

is now. 

[Laughter.] 

Mr. FRIEDMANN. One of the findings of that report was that in 

a carbon constrained world, the market share for coal will drop 

dramatically without carbon capture and storage. Another finding 

is that if carbon capture and storage is deployed in a carbon constrained world, that in fact coal can have a bright future. 

And what we have in fact seen is what those findings predicted; 

that the global market share for coal is beginning to drop and part 

of the reason why, by no means the only reason why, but part of 

the reason why is the carbon risk associated with those coal 

projects. 

And even in areas where people expected long sustained growth 

in carbon dioxide emissions from coal plants, like in India, like in 

China, it is clear that the governments of those countries are taking aggressive action to limit the deployment of coal plants in part 

because of the carbon risks. 

Senator CARPER. All right. Thank you. 

90 

Kind of a wrap up question for the whole panel. When we have 

a panel like this, one of the things that is very helpful is for you 

to help us develop consensus; and I think you are doing that today, 

whether you want to or not. But I want to ask each of you to just 

briefly tell us maybe something that you think we ought to take 

away from this hearing that will help further develop consensus 

around this issue. 

Mr. Fry, who grew up in Virginia. Where in Virginia? 

Mr. FRY. Staunton. 

Senator CARPER. Staunton. 

Mr. FRY. Yes, sir. 

Senator CARPER. I know where Staunton is. Danville and Roanoke right here. 

Senator WHITEHOUSE. Lived in Crozet. 

Senator CARPER. Yes. 

Mr. Fry, give us one great take away to help further develop this 

evolving consensus around this issue. 

Mr. FRY. I think the greatest consensus in our discussion today 

is obviously the financial incentives required for CCUS. But, from 

my perspective, we also need to incentivize pipelines. It is a bit of 

a chicken and an egg scenario we have here. We have had companies come into Wyoming interested in projects, but since we don’t 

have these pipeline infrastructure, they have gone somewhere else. 

So, beyond the obvious 45Q and financial issues, we need infrastructure. 

Senator CARPER. All right, thank you. 

Mr. Greeson. 

Mr. GREESON. Like a broken record, I will say up-front capital 

costs and incentives to help to support financing those up-front 

costs. And right behind that, our project was blessed with the opportunity to pay for a pipeline as a part of the project because of 

the way we structured the ownership of the oil field. But that is 

clearly not something that is easily repeatable. Even our oil company partner said they would not repeat that model again. 

So pipeline corridors will be a challenge, right behind the financing. 

Senator CARPER. All right, thanks. 

Last word, Dr. Friedmann, Julio Friedmann. Down by the 

Schoolyard. 

Mr. FRIEDMANN. Thank you, Senator Carper. I think there are 

three points of consensus for the Committee. Two of them have already been mentioned. One of them is needing to close that financial gap through some policy option. Second is the need for pipelines and acting on pipelines. I would actually point people to the 

work done by the Great Plains Institute at the behest, actually, of 

Matt Mead and Governor Bullock in Montana to start working on 

pipeline infrastructure as part of a national agenda. 

The third point, which hasn’t been talked about as much but is 

also, I think, an easy point of consensus is an innovation agenda. 

We need to get more people at more universities, in national labs, 

small businesses, VCs, companies large and small working on innovation to make the performance better and the costs lower. And 

there are many ways to incent such things, but an innovation agenVerDate Aug 31 2005 13:29 Nov 07, 2017 Jkt 000000 PO 00000 Frm 00094 Fmt 6633 Sfmt 6633 S:\_EPW\DOCS\27318.TXT VERN
91 

da will undergird any American competitiveness going forward, 

and it is a critical piece of the wainscoting. 

Senator CARPER. All right, thanks. 

Gentlemen, have you ever heard of the leadership being provided 

by Senator Heitkamp on 45Q? Are you all familiar with that? 

Mr. FRIEDMANN. Yes, sir. 

Senator CARPER. Do you think he is doing good work? 

[Laughter.] 

Mr. FRIEDMANN. I am sorry, I didn’t quite hear. 

Senator CARPER. Do you think she is doing good work? You are 

going to see her in about an hour. 

Mr. FRIEDMANN. The good news is that not only is she doing good 

work, but all of her partners, and Senator Barrasso, the Chairman, 

Senator Whitehouse, Senator Capito are all doing extraordinary 

work with this. 

Senator CARPER. I think they have me outnumbered, don’t they? 

Senator BARRASSO. We got you surrounded. 

Senator CARPER. Maybe I should talk to Heidi. 

Mr. FRIEDMANN. It is an opportunity to close that financing gap, 

and that is the most critical piece that needs to be done. Whether 

the Congress adopts it or not is not my business, that is your business, but some sort of policy structure like that is necessary to 

achieve liftoff. And if we are going to score, we need to take more 

shots on net. 

Senator CARPER. And what did Wayne Gretzky say? They used 

to ask Wayne Gretzky why do you take so many shots on goal. Do 

you remember what he said? I missed every shot I never took. How 

is that? That is a good note to close on, too. 

Thank you all very, very much. 

Senator BARRASSO. Senator Whitehouse. 

Senator WHITEHOUSE. Mr. Chairman, I just wanted to ask your 

permission to have Dr. Friedmann answer about the eight technologies that he described in the oceans as a question for the 

record so that we can get that into the record of the Committee. 

Senator BARRASSO. Absolutely. 

Senator WHITEHOUSE. And if that is OK with you, then I will 

proceed on that basis with Dr. Friedmann. 

And I thank the entire panel for their testimony. 

Senator BARRASSO. Thank you very much, Senator Whitehouse. 

And, of course, other members of the Committee may submit 

written questions. The hearing is going to stay open for 2 weeks, 

but I would ask you to respond in appropriate time to those written 

questions, as well as the one just brought forward by Senator 

Whitehouse. 

I appreciate all of you being here today. I thought it was a very 

productive hearing, very important information. I want to thank 

each and every one of you. 

This hearing is adjourned. 

[Whereupon, at 11:37 a.m. the Committee was adjourned.] 

[Additional material submitted for the record follows.] 

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BlUEGREEN 

September 26, 2017 

The Honorable John Barrasso 

Chairman 

U.S, Senate Committee on Environment and 

Public Works 

410 Dirksen Senate Office Building 

\\7ashington, D.C. 20510 

The Honorable Thomas R. Carper 

Ranking Ivfember 

U.S. Senate Committee on Environment and 

Public Works 

456 Dirksen Senate Office Building 

Washington, D.C. 20510 

RE: Expanding and Accelerating the Deployment and Use of Carbon Capture, Utilization, and 

Sequestration 

Dear Chairman Barrasso and Ranking lvfember Carper: 

As a coalition of the nation's largest labor unions and environmental groups, collectively 

representing millions of members and supporters, we write to express support for your committee's 

efforts to address the deployment and use of carbon capntre, utilization, and sequestration. 

Carbon capture and sequestration (CCS) is a rapidly growing technology that has potential to create 

economic benefits for multiple industries while significantly reducing carbon dioxide (CO:;) 

emissions. According to the Intergovernmental Panel on Climate Change (IPCC), the world will not 

be able to achieve its goal of limiting global surface temperature rise to 2 degrees Celsius without 

carbon capture. The IPCC further concluded that without CCS, the costs of mitigating climate 

change could increase by 138 percent, an investment estimated to total $2 trillion over the next 40 

years. 

Industrial facilities, in particular, are huge sources of carbon emissions, and very few solutions exist 

beyond carbon capture technologies to reign in these emissions . .According to the EPA, currently, 

direct emissions from industrial activities account for 21 percent of annual U.S. GHG emissionstotaling 6,587 MMTC01e annually. While these numbers are projected to decrease slightly, they will 

remain a large share of lJ .S. emissions in the future. Carbon capture is necessary to limit emissions 

from industrial activities because for many manufacturing processes, there are few alternatives for 

controlling emissions. Industrial facilities are the easiest, lowest cost targets for deploying CCS 

technologies, since they often produce pure streams of carbon dioxide that can be easily captured, 

Recent DOE investments in the industrial sector have stored 12 million metric tons of C01 safely 

and effectively. However, current federal incentives for CCS do not apply to industrial facilities, so 

CCS is not being used to its fullest potential in the sector. 
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Industrial facilities that capture and sell C02 will reduce their emissions while also gaining an extra 

revenue stream, creating jobs in their company as well as downstream industries and suppliers. The 

economic benefit of this would encourage more carbon producers to capture their emissions, and 

could result in reduction of stationary source C02 emissions from current levels. Adoption of CCS 

also means that '\Ve can find more effective ways to safely utilize C02 emissions in ways that do not 

damage the environment. C02 is already used in some industrial processes, and has the potential to 

shift from a burden to a valuable commodity in the future as research into safe carbon utilization 

advances. One example of a potential use is bio~refining. Micro-algae are incredibly efficient at 

processing C02, and some have been engineered to create biofuels and other useful chemicals. 

There is also research into converting C02 into advanced chemicals and materials, including 

concrete. 

Federal investment and incentives are necessary to provide short-term financing and encourage 

industrial C02 producers to build the infrastructure for and invest in CCS. One major barrier is a 

lack of incentive for industrial facilities to implement CCS. 1be quickest and most effective way to 

encourage the rapid deployment of CCS for industrial uses is extending and expanding the 45Q tax 

credit, which is provided to facilities that implement CCS technologies. This tax credit recently 

expired, and it only covers facilities that produce over 500,000 tons of carbon per year, which rules 

out major carbon producers like ethanol and other industrial facilities. The 45Q credit should be 

expanded to include more types of facilities, and incentives must be increased, especially for 

industrial facilities that sequester captured emissions. 

Federal efforts in this space should also consider the infrastructure associated with carbon capture. 

Right now, there are over 4,500 miles of carbon dioxide pipelines. Approximately 30 million metric 

tons of C02 are produced at industrial facilities within 50 miles of a C02 pipeline. However, to fully 

utilize CCS, several large corridors for pipelines from industrial regions like the hiidwest and the 

Gulf Coast, to locations where the carbon can be sequestered or othet\v:ise beneficially used, need to 

he built. Expanding this pipeline infrastructUie is a win-win solution for all involved. lt could drive 

billions of dollars of capital investment) stimu1ate economic activity, and support thousands of 

quality jobs in construction, manufacturing, and related fields. 

\Ve thank you for considering this important topic and urge you take our recommendations into 

consideration. 

Sincerely, 

KimGias 

Executive Director 

BlueGreen Alliance 
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Executive Summary 

The Global C02 Initiative (GCI) and CO. Sciences 

The Global C02 Initiative (GCI} focuses on funding research, development and commercialization of products that 

reuse C02• These products have the potential to reduce global annual carbon dioxide emissions by as much as ten 

percent. 

The GCI, announced in January 2016 at the World Economic Forum in Davos, aims to drive substantial economically 

based change by developing and harnessing market demand for products that capture and reuse co,. co, 

Sciences, Inc., GCI's non-profit, is structured to aggressively catalyze innovative research in carbon capture and use 

through grants to qualified applicants worldwide totaling $400 million over the next ten years. 

To carry out its mission, C02 Sciences is developing a '1oolkit' of capabilities and expertise (Figure 1} to assess 

market opportunities in the carbon-based products industry (CBPI), evaluate time horizons for short and long term 

opportunities, and identify a roadmap for implementation. 

Figure1: C02 Sciences Toolkit: Developing capabilities to adw:mce CBPI 

To date, we have completed a Market Assessment and Roadmap for Global Technology Implementation. This 

document provides a summary of the results of our market assessment study (released earlier this year) and, in 

greater detail, the results of work to develop a roadmap for global implementation of CBPL We conclude with 

recommendations for strategic actions. 

Market Assessment - A briefing 

C02 Sciences commissioned an independent study to conduct a detailed assessment of the global market 

opportunity for C02-based products. The study identified a large number of potential products and used the following 

criteria to focus on 25 of them: 

1. Environmentallmpacl 

a. C02 potential: total amount of C02 that can be captured 

b. Permanence: length of time before the captured C02 is released 

2. Economic Impact 

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a. Willingness to pay: maximum price of C02 that can be paid while keeping a given product 

competitive 

b. Ease of Implementation: capital requirements, regulatory and market channel barriers 

The 25 products shown in Figure 2 span seven categories: 

Chemicals 

Figure 2: Examples of products that can be made from C02 

The assessment included a bottom-up analysis for each of these seven categories and concluded that: 

CBPI can significantly contribute to reducing carbon emissions. Our initial estimate is that over 10% of 

annual C02 emissions can be captured in these products. 

These products represent an annual revenue opportunity of $800 billion to $1.1 trillion. 

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Background: Confronting an urgent challenge 

The significant reduction of carbon emissions into the environment is crucial to averting a global c!lmato!ogical, 

economic, environmental and political catastrophe. While renewable power generation and a number of adaptation 

options can help with C02 reduction, experts agree that carbon negative technologies are needed to keep 

temperature increases below 2'C (Figure 3). 

60 

55 

50 

45 

40 

35 

30 

25 

20 

15 

10 

5 

0 

Historical growth rate 

(1990-2013) 

Future growth rates (2013-2050) 

Except for INDC scenario 

which is up to 2030 

6 degree 

4 degree 

INDC2 

2 degree 

1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050 

Figure 3: Negative carbon emission rates are needed to limit temperature increase to i' C. 

CBPI represents a major carbon reduction technology that, prior to the GCI, has not received attention nor been 

explored in any comprehensive fashion. As shown in Figure 4, CBPI can cover 15-20% of the projected gap between 

the 2"C goal and use of all currently identified solutions, 

Figure 4: CBPI can play a significant role in addressing gap to achieve a 2° future 

A Roadmap for the Implementation of Carbon Utilization Technologies (Executive Summary) COz Sciences and The Gk>ba! C02 lniHalive 
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Identifying and forecasting market opportunity 

Technology pathways assessment 

We have identified and analyzed 180 developers who, worldwide, are actively engaged in CBPI and, ultimately, in the 

development of C02-based products. A database of CBPI developers was compiled from multiple sources. These 

entities include start~ups, mid-sized companies, corporations, consortia and research institutes. 

Following in depth technology assessment, we defined six markets or product clusters (Figure 5) based on the 

number of active developers, conversion technology pathways and targeted end products: 

1. Chemical intermediates (such as 

Methanol, Syngas and Formic acid) 70 2. Fuels (such as Methane and Liquid fuels) 

3. Building materials (such as Concrete and • 28 Aggregates) 

4. Algae (processed separately to create ,,,, ... 24 

biofueis or food additives) 

5. Polymers (such as polycarbonates, *B 21 polyurethane and PHA) 

6. Novel materials (such as carbon fiber) -15 

IIIII- 20 

60 

Figure 5: Number of active developers by end-product 

market cluster 

Four markets are recommended for funding and investment 

For each product or product category, we applied a Technology Readiness Level (TRL) of 1 (least) to 9 (most) to 

determine the relative stage of development and create a framework for expected time-to-market. We also used 

standardized rubrics to better quantify the mitigation potential and technology fit of each market. As a result, four 

markets were recommended for further analysis as shown in Figure 6. Algae and novel materials will not be part of 

the roadmap development as they will not significantly impact markets before 2030. 

The roadmap analysis focused on eight categories within these four markets: 

1. Chemical Intermediates: Methanol 

2. Chemical Intermediates: Syngas 

3. Chemical Intermediates: Formic acid 

4. Fuels: Methane 

5. Fuels: Liquid fuels 

6. Building materials: Concrete 

7. Building materials: Aggregates 

8. Polymers 

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Addressable 

Building materials 

Chemical intermediates 

Figure 6. Markets that offer the best opportunities for support and investment 

Market sizing 

The study estimated the 2015 market size and compound annual growth rates (CAGR) lor each of the eight 

categories within the four markets. The findings were based on existing proprietary research and secondary 

information from annual reports, published market studies and industry publications. Figure 7 indicates the 

methodology used in assessing markets. 

Figure 7. The methodology we used in assessing CBPI markets 

We then projected each product's market penetration rate based on three scenarios: 

Best case: Strategic actions are taken that remove barriers at earliest possible opportunity. 

Optimistic: Strategic actions are taken to mitigate barriers. 

Pessimistic: Status quo is maintained. 

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Each of the eight categories has a timeline for 

mitigating technology, policy and business barriers 

and driving market penetration. The study then 

estimated addressable market size by five-year 

milestones (2020, 2025 and 2030). Figure 8 presents 

an example of that analysis showing the potential for 

one building material market segment (concrete 

curing) to absorb C02 over the next 15 years. Similar 

analysis was conducted for the remaining seven 

categories. 

Drivers and barriers 

Figure 8: Estimated growth of CBPI concrete curing 

market through 2030 

Different market forces influence near term and long term potential of the different market segments. Market drivers 

include: 

The Paris agreement sets global goals for reducing C02 emissions and establishes a system to support 

national governments in doing so. These agreements entered into force in early November 2016. 

The drive toward a carbon-neutral economy and less dependence on oil. 

Working against these drivers are barriers including: 

Lack of coherent government funding strategies to support CBPI technologies. 

Lack of access to facilities to scale-up CBPI technologies. 

Lack of access to feedstocks -for hydrogen, C02 and renewable energy. 

Cost: CBPI must compete with conventional feedstock and bio-based feedstocks, which are often lower in 

cost. 

In general, these drivers and barriers can be examined by considering the respective roles of Technology, Market 

and Policy. 

In some cases, technology may be the largest barrier while, in others, the largest barrier may be policy. Figure 9 

illustrates the relative influence (1 low to 5 high) of policy, technology and market on the development of different 

products. For example, policy has a greater impact on the development and market penetration of fuels than on 

polymers. 

Fig. 9 Relative influence of the dimensions on different COr based products 

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Recommendations for Strategic Actions 

Consideration of the drivers and barriers enables us to develop the following recommendations to leverage the 

drivers and diminish the barriers. 

Technology: 

1. Decrease the cost of C02 utilization: Fund research to improve catalysis for C02 reduction and 

electrolysis to produce hydrogen. 

Research is needed to reduce the energy requirements of C02 catalysis and other conversion processes. A 

hydrogen feed is needed in the production of many C02-based products. To make CBPI more costcompetitive, applied research is needed in generating low cost H2 by electrolysis using renewable energy. 

2. Maximize high-potential long shots: Fund applied research on long-shot technologies and 

applications that have the highest C02 abatement potential. 

Market 

In addition to the four markets analyzed in this work, there are early-stage CBPI technologies and 

applications that could offer solutions beyond 2020. One of the highest-potential technical areas in this 

regard is the production of carbon fiber. Figure 10 depicts a potential timeline for implementing the 

technology levers. 

Strategk a<tions 

Timeline for deployment at scale 

Figure 1.0: Potential timeline {or implementing Technology levers 

1. Scale up production: Make funding available to establish collaborations among research institutes, 

start-ups, governments and corporations for process integration of C02 conversion, hydrogen 

generation and carbon capture. 

Consortia should be established to develop CBPI value chains, integrating carbon capture; the supply of 

affordable hydrogen from sources such as a chemical plant or a technology like electrolysis; access to lowcost renewable energy (such as over-capacity electricity); and physical plants for C02 conversion and CBPI 

product manufacturing. 

2. Access to Capital: Articulate and communicate the value proposition for CBPI technologies. 

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Polley 

As the market potential for CBPI solutions has only recently been identified by the CO, Sciences market 

assessment and global implementation roadmap, the value proposition is generally unknown by investors. 

Articulating and communicating the value proposition will increase the availability of capital and particularly 

impact investments that consider both social and financial returns. We are not implying inferior financial 

returns but emphasizing the double bottom line returns nature of investing in C02-based products. This 

captlal will enable faster adoption and market deployment of C02-based products. Figure 11 depicts a 

potential timeline for implementing the market levers. 

Timeline for deployment at scale 

Figure 11: Potential timeline for implementing market levers 

Supportive policies can help start and build markets for CBPI products. Different policies may be appropriate in 

different jurisdictions, depending on local circumstances. The following are policies that can play an important role in 

promoting CBPI products. 

1. Government and Industry support for R&D: Support lor R&D on carbon dioxide utilization is currently 

modest. A significant increase in funding in this area could speed deployment of CBPI technologies and 

yield important dividends. In December 2015, heads of state from more than 20 countries announced 

Mission Innovation, a pledge to double R&D on clean energy within five years. The increase in government 

R&D budgets offers an important opportunity to scale up R&D funding for C02 utilization. Support from 

corporations and other private funders {e.g. philanthropists) for R&D can also serve to accelerate progress 

on new technology creation. 

2. Carbon Price: A price on carbon dioxide emissions, whether through an emissions trading program or tax 

mechanism, would provide emitters with an important incentive to cut emissions. 

3. Mandates: Governments could mandate the use of C02 in certain products as a means to spur the market. 

4. Government procurement: Government (including military) procurement can provide early market demand 

for emerging technologies, such as the US Navy's procurement of biofuels. 

5. Credits under regulatory and voluntary programs: Governments could offer additional credits under 

existing regulatory programs tied to the use of CBPI products. 

The implementation of the above cited levers will lead to significant increase in C02 reduction (Figure 12) 

and will create significant business opportunities (Figure 13). 

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2020 2025 2030 

Aggregates 

Fuels 

Concrete 

Methanol 

0.000028-·0 000058 0.000048 

Polymers 

Figure 12: Potential C02 reduction due to implementing strategic actions 

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2020 2025 2030 

COcm:rate 

Fuels 

Aggregates 

Methanol 

Figure 13: Potential increase in financial returns due to Implementation of strategic actions 

A Roadmap for the lmpfemen!a!ion of Carbon Utilization Technologies (Executive Summary) COz Sciences and The Global C02 Initiative 10 
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Conclusions 

The Carbon Based Products Industry (CBPI), created through broad scale commercialization of 

products derived from C02, offers a huge opportunity to mitigate C02 emissions driven by market 

returns. 

C02 mitigation and CBPI are critical to decrease the risks associated with climate change. CBPI utilizes C02 

to produce valuable materials, fuels or chemicals, whereas mitigation strategies like carbon capture and 

storage represent only an economic cost to society. 

Over the past five years, significant progress has been made on research and development of CO,·based 

products. Many technologies are proving to be scalable. There is visible momentum in four major markets: 

building materials, chemical intermediaries, fuels and polymers. 

Funding, incentives and prompt strategic action are necessary to move the CBPI to its full potential. At its full 

potential scale, our most recent global roadmap shows that the CBPI could reach or exceed US $800 

billion by 2030 and, critically, the Carbon Based Products Industry has the potential to utilize seven 

billion metric tons of C02 per year by 2030 - the equivalent of approximately 15 percent of current 

annual global C02 emissions. The path to a 2' future depends on it. 

A Roadmap for the Implementation of Carbon Utilization Technologies (Executive Summary) C02 Sciences and The Global C02 Initiative 11 

27318.059

U.S. Basins Favorable for C02-Enhanced Oil Recovery 

Alaska 

Source: Advanced Resources International. 
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Enhanced Oil Recovery (EOR) using industrial C02 provides 

an important way to stimulate the development of the 

infrastructure needed to capture and store large amounts of 

C02 consistent with decarbonizing the energy system. 

According to the International Energy Agency (lEA), utilizing 

industrial C02 Enhanced Oil Recovery for the purposes of 

Carbon Capture Utilization and Storage (CCUS) results in a 

net C02 emissions reduction. 

Based on lEA's analysis CCUS-EOR using industrial C02 can 

result in a 63% net reduction in C02 emissions for every barrel 

of oil produced. 

If we do not take advantage of C02 EOR, the oil may be 

produced by other technologies that do not reduce emissions. 
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According to the lEA, there is a potential to store 140 billion tons of C02 in oil reservoirs around 

the world through C02 EOR1 - resulting in a net emissions reduction by 88 billion tons of C02. 

This is more than 40 times the current U.S. power sector emissions. Thus, under the right 

economic conditions there would be a large market-based opportunity to reduce man-made 

C02 emissions. As a result, enhanced oil recovery activity using captured anthropogenic C02, 

could significantly drive the deployment of CCUS technology & infrastructure, and help lower 

technology costs around the globe. 

Can C02 EOR provide a net reduction in co, emissions? 

Yes. CCUS combined with EOR involves the incidental geologic trapping or storage of C02 that 

occurs as part of the oil recovery process. C02 is injected into mature reservoirs, where it mixes 

with the remaining oil, enabling it to be more easily produced, and as a result of which a 

portion of the C02 (usually about one-third to a half) is geologically trapped, permanently. The 

C02 that is not trapped is produced with the oil, recaptured, and reinjected- and the process 

continues until all of the C02 is permanently sequestered. 

Over the life of the project, almost all of the C02 delivered to the field is stored in the geologic 

formation. But because EOR produces oil, which when processed or used produces emissions, 

the stored volume of C02 cannot entirely be counted as an emissions reduction. When the 

volume of C02 stored underground is greater than those emitted by the excess emissions 

caused by EOR activity, then the difference must be counted as a net emissions reduction 

benefit. 

The most recent and comprehensive assessment of net storage from C02 EOR was developed 

by the lEA in 2015. 2 The study indicates that for a given volume of C02 delivered to an oil field 

or storage site, EOR can provide a 63% net emissions reduction benefit, under the reasonable 

assumptions outlined below. 

CLEAN~ TASKFORCE 
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Net in 

Figure 1 shows the benefits of C02 EOR in terms of C02 emissions reduction. The production 

and consumption of a typical barrel results in about half a metric ton of C02 being emitted to 

the atmosphere. 

No. Producing a barrel of oil from C02 EOR is slightly more energy intensive than a conventional 

barrel of oil, with emissions of 0.54 metric tons and 0.51 metric tons of C02 respectively. But 

CO, EOR has the benefit of storing the 0.30 metric tons of C02 that was needed to produce 1 

barrel of oil. After accounting for this benefit, the production and consumption of a barrel of oil 

from EOR contributes a net of 0.24 metric tons of C02 to the atmosphere. 

If an EOR barrel replaced a barrel of conventionally produced oil in the market, then there 

would an emissions reduction of 0.27 metric tons of C02 per barrel (the difference between 

conventional oil emissions and EOR barrel emissions). In reality though, all else being equal, this 

1 to 1 displacement does not occur. The new oil supply will lower the market price of oil and 

thus increase the demand for oil. The lEA estimates that for every 10 barrels of oil produced 
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through C02 EOR, only 8 barrels of existing oil are displaced and 2 barrels are additional. The 

displacement of the 8 barrels (or 80% of existing supply) provides an emissions reduction 

benefit of 0.23 tons per EOR barrel.3 But, the increase in consumption of the additional 2 EOR 

barrels (20% of existing supply) increases emissions by 0.04 tons per EOR barrel.4 These market 

effects result in a net emissions reduction benefit to 0.19 metric tons of C02 per EOR barrel, on 

average. 

Considering the C02 used for EOR is anthropogenic, i.e. captured from the power or industrial 

sectors and which would otherwise be released into the atmosphere, the net reduction of C02 

is 63% per barrel of oil produced or per 0.3 tons injected (or, per any other volume of C02 

injected). 

The type of oil production that is assumed to be replaced by EOR is also a key factor in 

determining the net reduction in emissions. The lEA analysis found that net emission reductions 

could range from 47% to 150% depending on the carbon content of the oil that is assumed to 

be offset. While a 20% increase in oil consumption driven by C02 EOR oil production delivers 

net emissions reduction, even if the consumption increased by 50% of a barrel, there would still 

be a net emissions reduction benefit. 

Yes, emissions upstream from the C02 EOR process can also affect the C02 emissions reduction 

benefits from using anthropogenic co,. But, it is important to note that the upstream emissions 

affect any sequestration method the same exact way. In other words, upstream emissions 

affect both EOR and storage in deep saline geologic reservoirs equally. Hence, it is only 

downstream emissions that provide the crucial "apples to apples" net emissions reductions 

benefit comparison. 

Upstream emissions include those from coal and natural gas production, transportation of fuel, 

combustion and transportation of captured C02• But, the key emissions impact is driven by 
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capture technology and configuration (new/retrofit/full or partial capture) used at the emitting 

source. For example, if we were to include in our upstream calculations a 90% capture from a 

retrofit on an existing coal plant using current conventional capture technology, then it would 

reduce the emissions reduction benefit from C02 EOR by 25%, due to process energy penalties 

and capture rates. 6 Alternatively, if we were to consider an advanced carbon capture 

technology such as one based on the Allam Cycle, which could reach 100% capture levels, 

bringing the energy penalty to minimal levels, then the reduction in the benefit from 

downstream C02 EOR would be minimal.7 

Would the_gj!_fr_~l!l.ll.I)P.l~~ed_Qlill!!lds_~.l:l~QQYSed alii''!'IilY_IIII_lthout CO?£c:l.Rl 

Likely. The same oil that is targeted for CO, EOR, can be produced by other technologies and 

will only result in increased emissions. Oil from depleted wells will be recovered using the best 

available method, even if it is not C02 injection, if the oil prices so dictate. C02 EOR is effectively 

in competition with other EOR options outlined below. These options do not provide any 

climate benefit, but instead only permit and lead to increased C02 emissions. 

Geologically-sourced C02 has been in use for several decades for C02 EOR. 75% of the C02 

currently used for EOR is produced from natural geologic deposits. National Energy Technology 

Laboratory {NETL) estimates that there are an additional 3.9 billion metric tons of geologicallysourced C02 in the US that could be produced economically for use in EOR8 Because the 

natural-sourced C02 was already geologically trapped, it does not deliver a climate benefit 

when used for C02 EOR, unlike industrial-sourced C02• 

The use of surfactants, polymers, and detergents for chemical flooding in reservoirs is another 

form of enhanced oil recovery. Advances in drilling such as infield drilling, horizontal drilling 

and fracking could also be used to extract the oil from reservoirs, which would otherwise be 

targets for C02 injection. 
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Methane reacts in oil fields in a manner similar to C02• The Norwegian oil company Statoil has 

been injecting methane into the North Sea for oil recovery (64 million metric tons /year) in 

amounts that are similar to those of C02 injected into the Permian Basin in Texas for EOR. 9 

Methane is also regularly injected into the North Slope formation also for EOR. Although EOR is 

typically not the way to extract the most economic value out of methane, it is still used in some 

regions where either C02 is not available or oil-gas price arbitrage drives a preference for 

methane injection to produce additional oil. 

Conclusion 

Enhanced Oil Recovery using captured industrial C02 can provide a net C02 emissions reduction 

of 63% relative to the C02 stored, taking into account emissions from oil consumption. The 

combination of the existing and projected demand for EOR and the availability of industrial C02 

offers the potential for developing the needed infrastructure to more widely deploy CCUS 

technology at a significant scale and to store large amounts of C02. Without C02 EOR using 

captured industrial (anthropogenic) C02, the oil will likely be produced anyway, using other 

methods of extraction that do not provide emissions reduction benefits. 

1 lEA Greenhouse Gas R&D Programme (lEA, GHG), "C02 Storage in Depleted Oilfields: Global Application Criteria 

for Carbon Dioxide Enhanced Oil Recovery, 2009112, December 2009." 

2 International Energy Agency, "Storing C02 through Enhanced Oil Recovery, combining EOR with C02 storage 

for profit," 2015. 

The more precise lEA displacement estimate is 84%. Multiplying that with the difference between conventional oil 

and EOR oil (0.27 metric tons per bbl) results in a net benefit of 0.23 metric tons per bbL 

4 The more precise lEA displacement estimate is 16'%,. Multiplying that with the emissions from one barrel of EOR oil 

(0.24 metric tons per bb!} results in a net increase of 0.04 metric tons per bbL 

5 International Energy Agency, "Storing C02 through Enhanced Oil Recovery, combining EOR with C02 storage 

(EOR+) for profit," 2015. 

6 Calculated from spreadsheet model developed for Azzolina, et a!., "How green is my oil? A detailed look at 

greenhouse gas accounting for C0 ~enhanced oil recovery (C0 ~EOR) sites." International Journal of Greenhouse 

Gas Control 51 (2016) pp. 369-379. Considering coal plant retroti! with 90% capture level, 30% energy penalty and 

make up power from NGCC without carbon capture (no displacement of electricity grid mix}. 

7 NETPower brieting to USEA, May 25, 2016. 

8 National Energy Technology Laboratory, "Subsurface Sources of C02 in the Contiguous United States Volume i: 

Discovered Reservoirs," March 4, 2015, DOEINETL-201411637. 9 Cavanagh, Ringrose, Statoil, ASA 

recycling in Europe to CCUS in North 
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Staff Report to the Secretary on 

Electricity Markets and Reliability 

August 2017 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
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Table of Contents ............................................................................................................................... . 

list of Figures ..................................................................................................................................... . 

list of Tables ..................................................................................................................................... .. 

1 Introduction ............................................................................................................................... 1 

2 Findings of This Study ............................................................................................................... 10 

3 Power Plant Retirements .......................................................................................................... 15 

3.1 Coal Plant Retirements ............................................................................................................... 20 

3.2 Natural Gas Plant Retirements ................................................................................................... 24 

3.3 Nuclear Plant Retirements .......................................................................................................... 27 

3.4 Hydropower Retirements and Repowering ................................................................................ 34 

3.5 Falling Natural Gas Prices ............................................................................................................ 35 

3.6 Environmental Regulations ......................................................................................................... 39 

3. 7 Growing VRE Deployment ........................................................................................................... 47 

3.8 Flattening Electricity Demand ..................................................................................................... 54 

3.9 Power Plant Retirements Looking Forward ................................................................................ 57 

4 Reliability and Resilience .......................................................................................................... 61 

4.1 Assessing Challenges to Reliability .............................................................................................. 53 

4.2 Diversity, Fuel Assurance, and Onsite Storage ........................................................................... 89 

4.3 High-Risk Events and System Resilience ..................................................................................... 97 

4.4 Enhancing Reliability and Resilience ........................................................................................... 99 

4.5 Reliability and Resilience Looking Forward ............................................................................... lOO 

5 Wholesale Electricity Markets ................................................................................................. 102 

5.1 Evolution of U.S. Wholesale Electricity Markets ....................................................................... 102 

5.2 Wholesale Electricity Markets Today ........................................................................................ 104 

5.3 Challenges in Wholesale Electricity Markets ............................................................................ 107 

5.4 Wholesale Electricity Markets looking Forward ...................................................................... 118 

6 Affordability ........................................................................................................................... 119 

6.1 Affordability of Generation Portfolios ...................................................................................... 119 

6.2 The Wholesale-Retail Disconnect ............................................................................................. 120 

6.3 Affordability Looking Forward .................................................................................................. 124 

7 Policy Recommendations ........................................................................................................ 126 

8 Areas for Further Research ..................................................................................................... 128 

Appendix A: National and Regional Profiles ................................................................................... 130 

Appendix B: VRE Integration Studies .............................................................................................. 151 

Appendix C: Power Plant Cycling ................................................................................................... 154 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
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Existing coal-fired power plants must not only comply with all Federal requirements related to emissions 

and water use, wastewater treatment, and solid waste management, but also with any additional 

applicable state regulations. 134 Cost impacts of these regulations varied. The EPA reported that a typical 

coal-fueled unit with a capacity of 700 MW could incur incremental operating and maintenance costs 

ranging from $287 million to $351 million to install a scrubber, from $116 million to $137 million to 

install a selective catalytic reduction unit, and from $97 million to $114 million to install a baghouse 

(fabric filter). Fitch estimated the lifetime costs and reduced cash flow associated with environmental 

retrofits at $1,700-$1,900 per kilowatt (kW) for a 100 MW plant burning bituminous coal, as compared 

with a range of $1,20Q-$1,300/kW for a 500 MW plant. 135 These costs are on par with those of 

constructing a new typical (i.e., subcritical) coal plant of similar size during this same time period 

(averaging $1,361/kW)."6 Reported planned retirements from that time suggest that approximately 

27,000 MW or 8.5 percent of 2011 coal-fired capacity was rendered uneconomic under the combination 

of regulatory compliance costs, little demand growth, and falling natural gas prices. 131 

The MATS rule was potentially the most expensive and immediate ofthe suite of pending regulations, 

with a compliance deadline of April 2015 (later extended to April 2016 for some plants). Further, owners 

of coal facilities were dealing with MATS compliance in combination with the cost of imminent 

additional regulations of co,, along with other GHGs. EIA reported that by the end of 2012, 64 percent 

of the U.S. coal generating capacity in the electric power sector already had the appropriate 

environmental control equipment (most reported using flue gas desulfurization) to comply with the 

MATS rule and operate past 2016; another six percent planned to add control equipment; 10 percent 

had announced plans to retire; and the other 20.4 percent still had to decide whether, how, and when 

to upgrade or retire their plants. 138 

The dominant MATS compliance strategy among coal-fired plant owners was to install activated carbon 

injection (Figure 3.22), which averaged a relatively modest $5.8 million per generator from 2015 to 

2016. EIA estimates that "operators invested at least $6.1 billion from 2014 to 2016 to comply with 

MATS or other environmental regulations."139 1n its rulemaking, EPA estimated an annualized cost of 

$9.6 billion in 2015, declining to $7.4 billion annually in 2030. 140 

Staff Report on Electricity Markets and Reliability 

43 

U.S. Department of Energy 
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gigawatts (GVV) 2016 

0 20 40 80 

The retrofit-or-retire decision for owners is also impacted by EPA's New Source Review (NSR) regulations 

that can affect owners' ability to enhance plant efficiency due to the delay, cost, and uncertainty 

associated with obtaining an NSR permit. The NSR permitting program requires stationary sources of air 

pollution-including factories, industrial boilers, and power plants-to get permits before construction 

starts, whether the unit is being newly built or modified. 142 This is an important concern for owners 

considering retrofitting an existing power plant with carbon capture equipment to reduce co, emissions, 

or adding new components to improve operating efficiency. These upgrades could trigger the NSR 

requirements of the Clean Air Act because they would constitute a "physical change," or lead to a 

designation of the change as a "major modification," subjecting the unit to NSR permitting 

requirements. 

The uncertainty stemming from NSR creates an unnecessary burden that discourages rather than 

encourages installation of co, emission control equipment and investments in efficiency because of the 

additional expenditures and delays associated with the permitting process. 143 144 Ironically, the 

uncertainty surrounding NSR requirements has led to a significant lack of investment in plant and 

efficiency upgrades, which would otherwise lead to more efficient power generation, benefits to grid 

management, and reduced environmental impacts. EPA has acknowledged these burdens and has made 

attempts to reform the rules to improve and streamline NSR: 

The NSR program distinguished between "routine maintenance and repair" of existing facilities-which 

would be allowed-and more "substantial modification" of existing facilities, which would put the 

facilities over the threshold and thus require them to meet new emissions standards. 

Environmentalists argued that owners of electric generation and industrial plants were building virtually 

new facilities from the inside out by exploiting the "routine maintenance and repair" exclusion from 

NSR. EPA changed its interpretation in the 1990s to a more rigorous standard, culminating in numerous 

enforcement-related lawsuits beginning in the late 1990s.'46 

44 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
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By the late 2000s, some older coal units operating without pollution controls were no longer operating 

as baseload units, having operational capacity factors estimated at 47 percent to 56 percent.147 As Figure 

3.23 shows, rather than acting as baseload units at high capacity factors, these older units (with an 

average capacity of 109 MW) were operating at falling capacity factors. The units that retired in 2014 

had an average capacity factor of 13 percent in 2013. 

80% 

70% 

76% 

60% 53% 

20% 

10% 

0% 

2008 

69% 

2009 

Source EIA Form 860 and Form 923 

71% 

2010 2011 2012 2013 2014 

llllallcoal retiring 2014 

Some owners delayed their retirement announcements and retrofit decisions in order to see how the 

regulation litigation challenges played out, in case a late court ruling made compliance unnecessary, 

signifying that the cost of complying with those regulations was a factor in their retirement decisions. 

Others delayed closing uneconomic plants to see if enough other plants retired, in hopes that the 

resulting shift in market dynamics and prices might render the unretired plants profitable again. 149 

Figure 3.24 shows total U.S. coal capacity from 2008 through mid-2016 and projections through 

mid-2018. While there was a fall in coal plant capacity in 2015 associated with the MATS compliance 

deadline, EIA finds that fewer coal facilities retired in 2015 and the first half of 2016 than EIA had 

projected ahead of the compliance deadline. Specifically, in 2015 and until the April 2016 extended 

MATS deadline, about 20,000 MW of coal capacity retired and another 9,000 MW of coal capacity 

converted to natural gas, while EIA projected 50,000 MW of retirements between 2013 and 2020, with 

the majority retiring in 2015 in response to MATS. 150 However, EIA's projection also included other 

factors that can drive retirement decisions, such as the Clean Power Plan. 

45 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
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average deliVered tue! cost 

dollars per megawatthour ($1MWh 1 

prqections 

120 

100 

80 

Because natural gas emits far less air pollution than coal-fired power plants, 152 the regulatory burden 

and cost to natural gas-fired power plants is much lower than for coal plants. ERCOT's December 2014 

analysis estimated that the Cross-State Air Pollution Rule (CSAPR)I' and the Cooling Water Intake Rule 

would impose moderate compliance costs on natural gas-fired power plants. 153 Specifically, ERCOT 

estimated costs of $0.10-$2. 75/MWh for CSAPR and $0.10-$0.50/MWh for the Cooling Water Intake 

Rule. 

The large majority of natural gas plants that have retired are NGSTs, which are less efficient than the 

newer NGCCs.l54 From 2002 to 2016, there was a steady stream of NGST retirements, some of which 

may be linked to decisions about the cost effectiveness of retrofit upgrades. However, during the period 

2014-2016, 23,500 MW of new natural gas capacity was added, nearly double the total natural gas 

capacity that was retired as part of the transition from NGST units to more efficient NGCC units.155 NGCC 

plants have replaced NGST plants for baseload use and natural gas combustion turbines have been built 

for peak power demand. 

The principal environmental regulation affecting nuclear power plants is the Cooling Water Intake Rule, 

which applies to all types of power plants but is most challenging for nuclear plants. A revised version of 

the Cooling Water Intake Rule has been in effect since 2003. The rule was promulgated to protect 

aquatic life. States may decide how to implement the rule, such as by requiring a nuclear (or other) plant 

to invest in a closed-loop cooling system to replace once-through ocean or waterway cooling. Three of 

the nuclear plants that have announced closures (Oyster Creek in New Jersey, Diablo Canyon in 

iJ Finalized in 2011 and effective in 2015. 

46 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
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The April14 memo asked staff to "not only analyze problems but also provide concrete policy 

recommendations and solutions." To that end, DOE staff prepared a list of recommendations below. 

Some actions fit squarely within DOE's authority, while others might fall to other government agencies 

or private organizations. 

Wholesale markets: FERC should expedite its efforts with states, RTO/ISOs, and other stakeholders to 

improve energy price formation in centrally-organized wholesale electricity markets. After several years 

offact finding and technical conferences, the record now supports energy price formation reform, such 

as the proposals laid out by P JM467 and others.468 Further, negative offers should be mitigated to the 

broadest extent possible. 

Valuation of Essential Reliability Services (ERS): Where feasible and within its statutory authority, FERC 

should study and make recommendations regarding efforts to require valuation of new and existing ERS 

by creating fuel-neutral markets and/or regulatory mechanisms that compensate grid participants for 

services that are necessary to support reliable grid operations. Pricing mechanisms or regulations should 

be fuel and technology neutral and centered on the reliability services provided. DOE should provide 

technical and policy support that strengthen and accelerate these efforts. 

Bulk Power System {BPS) resilience: DOE should support utility, grid operator, and consumer efforts to 

enhance system resilience. Transmission planning entities should conduct periodic disasterpreparedness exercises involving electric utilities, regional offices of Federal agencies, and state 

agencies. NERC should consider adding resilience components to its mission statement and develop a 

program to work with its member utilities to broaden their use of emerging ways to better incorporate 

resilience. RTOs and ISOs should further define criteria for resilience, identify how to include resilience 

in business practices, and examine resilience-related impacts of their resource mix. 

Promote Research and Development {R&D) of next-generation/21" century grid reliability and 

resilience tools: DOE should focus R&D efforts to enhance utility, grid operator, and consumer efforts to 

enhance system reliability and resilience. DOE R&D opportunities include the following activities: 

• Develop grid technical tools to facilitate new-generation technologies' operations to support 

BPS reliability (e.g., by enabling technologies to provide ERS), and maximize use of the DOE 

national laboratories. 

Expand cooperation on grid reliability across North America, including working with NERC to 

further enhance the reliability of our shared BPS through technical engagement with Mexico 

and Canada. 

With the National Science Foundation, sponsor the development of new open-source software 

for the next-generation electric grid research community. 

Focus R&D on improving VRE integration through grid modernization technologies that can 

increase grid operational flexibility and reliability through a variety of innovations in sensors 

and controls, storage technology, grid integration, and advanced power electronics. The Grid 

Modernization Initiative should also consider additional applications of high-performance 

computing for grid modeling to advance grid resilience. 

Support Federal and regional approaches to electricity workforce development and transition 

assistance: In partnership with other agencies and the private sector, DOE should facilitate programs 

126 

Staff Report on Electricity Markets and Reliability U.S. Department of Energy 
120 


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and regional approaches for electricity sector workforce development. Unemployed workers nearing but 

not yet eligible for retirement may have difficulty retraining after careers built on specialized skills that 

may be in declining demand. Where possible, Federal agencies should leverage existing government, 

nongovernment, labor, and industry workforce consortia. 

Energy dominance: Executive Order 13783 (Promoting Energy Independence and Economic Growth) 

outlined an approach to promote the clean and safe development of energy resources while at the same 

time minimizing regulatory barriers to energy production, economic growth, and job creation. The Order 

called for a rescission of certain energy and climate related policies, rescinded specific reports, and 

ordered the review of key environmental regulations. While DOE is not the main agency tasked in the 

Order, it should continue to prioritize energy dominance and implementing the Executive Order broadly 

and quickly. 

Infrastructure development: DOE and related Federal agencies should accelerate and reduce costs for 

the licensing, relicensing, and permitting of grid infrastructure such as nuclear, hydro, coal, advanced 

generation technologies, and transmission. DOE should review regulatory burdens for siting and 

permitting for generation and gas and electricity transmission infrastructure and should take actions to 

accelerate the process and reduce costs. Specific reforms could include the following: 

Hydropower: Encourage FERC to revisit the current licensing and relicensing process and 

minimize regulatory burden, particularly for small projects and pumped storage. 

Nuclear Power: Encourage the NRC to ensure the safety of existing and new nuclear facilities 

without unnecessarily adding to the operating costs and economic uncertainty of nuclear 

energy. Revisit nuclear safety rules under a risk-based approach. 

Coal Generation: Encourage EPA to allow coal-fired power plants to improve efficiency and 

reliability without triggering new regulatory approvals and associated costs. In a regulatory 

environment that would allow for improvement of the existing fleet, DOE should pursue a 

targeted R&D portfolio aiming at increasing efficiency. 

Electric-gas coordination: Utilities, states, FERC, and DOE should support increased coordination 

between the electric and natural gas industries to address potential reliability and resilience concerns 

associated with organizational and infrastructure differences. DOE and FERC should support wellfunctioning commodity markets for natural gas by expeditiously processing liquefied natural gas export 

and cross-border natural gas pipeline applications. 

Staff Report on Electricity Markets and Reliability Study 

127 

U.S. Department of Energy 
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National Coal Council- leveling the Playing Field 

CHAIR 

Jeff Wallace, Southern Company Services {retired) 

COAL POLICY COMMITTEE 

Fredrick D. Palmer, Peabody Energy (retired) 

STUDY CHAIR 

Glenn Kellow, Peabody Energy 

TECHNICAl CHAIR & lEAD AUTHOR 

Fred Eames, Hunton & Williams 

CONTRIBUTING AUTHORS 

Janet Gellici, National Coal Council 

Mark Menezes, Hunton & Williams 

Eric Hutchins, Hunton & Williams 

EDITOR 

Richard Guerard, Hunton & Williams 

EXECUTIVE VICE PRESIDENT & 

Janet Gellid 

The National Coal Council is a Federal Advisory Committee to the U.S. Secretary of Energy. 

The NCC advises, informs and makes recommendations to the Secretary on matters requested 

by the Secretary relating to coal or the coal industry. 

Library of Congress Catalog# 201596068 
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National Coal Council Leveling the Playing Field 

The National Coal Council (NCC) was chartered in 1984 based on the conviction that an industry advisory 

council on coal could make a vital contribution to America's energy security. The NCC's founders 

believed that providing expert information could help shape policies relevant to the use of coal in an 

environmentally sound manner. It was expected that this could, in turn, lead to decreased dependence 

on other less abundant, more costly, less secure sources of energy. 

These principles continue to guide and inform the activities of the NCC. Coal has a vital role to play in 

the future of our nation's electric power, industrial, manufacturing, and energy needs. Our nation's 

primary energy challenge is to find a way to balance our social, economic, and environmental objectives. 

Throughout its 30-year history, the NCC has maintained its focus on providing guidance to the Secretary 

of Energy on various aspects of the coal industry. The NCC has retained its original charge to represent a 

diversity of perspectives through its varied membership and continues to welcome members with 

extensive experience and expertise related to coal. 

The NCC serves as an advisory group to the Secretary of Energy, chartered under the Federal Advisory 

Committee Act (FACA), providing advice and recommendations to the Secretary of Energy on general 

policy matters relating to coal and the coal industry. As a FACA organization, the NCC does not engage 

in lobbying activities. 

The principal activity of the NCC is to prepare reports for the Secretary of Energy at his/her request 

During its 30-year history, the NCC has prepared more than 30 studies for the Secretary, at no cost to 

the Department of Energy. All NCC studies are publicly available on the NCC website. 

Members of the NCC are appointed by the Secretary of Energy and represent all segments of coal 

interests and geographic distribution. The NCC is headed by a Chair and Vice Chair who are elected by 

its members. The Council is supported entirely by voluntary contributions from NCC members and 

receives no funds from the Federal government. Studies are conducted solely at the expensive of the 

NCC and at no cost to the government. 

The National Coal Council values the opportunity to represent the power, the pride, and the promise of 

our nation's coal industry. 

National Coal Council 

1101 Pennsylvania Ave. NW, Ste. 600- Washington, DC 20004 

(202) 756-4524- =~==!J:A 
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National Coal Council- Leveling the Playing Field 

November 12, 2015 

The Honorable Ernest J. Moniz 

U.S. Secretary of Energy 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, DC 20585 

Dear Secretary Moniz: 

On behalf of the members of the National Coal Council (NCC), we are pleased to submit to you, 

pursuant to your letter dated September 18, 2015, the white paper "Leveling the Playing Field: 

Policy Parity for Carbon Capture and Storage Technologies." The white paper's primary focus is 

to recommend incentives and policies that can be employed to level the playing field for 

deploying CCS technologies. We are pleased to have completed this work through the NCC's 

newly formed rapid-response initiative, ensuring that your request for guidance could be 

provided in advance of the COP21 meeting in late November. 

The principal theme of the NCC's Leveling the Playing Field white paper is that federal policy 

has severely tilted the energy playing field. Existing incentives for CCS are simply too small to 

bridge the gap between the cost and risk of promising, but immature, CCS technologies vis-a-vis 

other low-carbon technology options. While the U.S. Department of Energy has stewarded a 

successful research and development program to spur early development of CCS technologies, 

insufficient overall support has hindered commercial deployment. 

Other low carbon technologies have benefitted from substantial government support. The 

success of policy and financial incentives afforded to the renewable energy industry provides 

ample evidence that government support can be the critical enabler for bringing scale and 

speed to clean energy technology deployment. 

The National Coal Council is pleased to offer a menu of options that can be employed to level 

the playing for CCS. These include financial incentives, regulatory improvements, and research, 

development and demonstration catalysts. No single incentive by itself will provide the parity 

needed to effectively deploy CCS technologies. The optimal mix of incentives will need to be 

evaluated and provided on a project-by-project basis. 
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National Coal Council- Leveling the Playing Field 

We are confident that this country will succeed in meeting our global carbon dioxide emission 

reduction goals when we commit with urgency to the deployment of CCS technologies. Such 

commitment begins with the establishment of policies and incentives to level the playing field 

for CCS. 

Thank you for the opportunity to prepare this white paper. The Council stands ready to address 

any questions you may have regarding its recommendations and other contents. 

Sincerely, 

Jeff Wallace 

NCC Chair 

Glenn Kellow 

NCC Study Chair 
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National Coal Council -Leveling the Playing Field 

;-,ernermJ<:r 18, 2015 

Mr. Jeffrey Wallace 

Chairman. The National Coal Council, Inc. 

II 0 l Pcnnsvlvania Avenue. NW. 6111 Floor 

Washingt01;, DC 20004 . . 

Dear Chaimwn Wallace: 

! am writing today to requ~st the National Coal Council 

that focuses on incentives and that can be Prrm~<we•.n 

deploying Carbon Capture (CCS) tcclul<Jlogies. 

a white 

playing for 

should focus on policy padty measures that advance CCS technologies. 

to be addressed are: 

(l) What incentives and policies can be employed to level the t1eld Hlr the 

dCJ)loyment of CCS technologies? This white paper an assessment 

""·"""'''and policies used to advance all the low-carbon technologies. 

(2) What are the to remove 

failures, adjust tax policies and utilize for clean energy 

technologies that could be employed to expedite and advance deployment of 

CCS? 

would be undertaken by the NCC's m!\NlV·!Ornlr:d F'"'""ti'J~" 

l3oard l ask that the white paper be cornplet•~d 

Paris in late November. 

Upon receiving this 

me of your schedule 

working with you in this 

your internal working groups. 

paper. The Department 

Sincerely, 

Ernest J. Moni;; 

advise 
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National Coal Council -leveling the Playing Field 

Advisory Group & Review Team 

EXECUTIVE ADVISORY BOARD 

Jeff Wallace, Southern Company (retired)- NCC Chair 

Mike Durham, Soap Creek Energy- NCC Vice Chair 

Fred Palmer, Peabody Energy (retired)- Coal Policy Committee Chair 

Bill Brownell, Hunton & Williams- Coal Policy Committee Vice Chair 

John Eaves, Arch Coal 

Kemal Williamson, Peabody Energy 

Rich lopriore, PSEG FossilllC 

Mike Sorensen, Tri-State Generation & Transmission 

George Duggan, BNSF Railway 

George McClellan, Clean Coal Solutions 

Mark Schoenfield, Jupiter Oxygen 

Janet Gellici, National Coal Council 

STUDY CHAIR 

Glenn Kellow, Peabody Energy 

TECHNICAl CHAIR & LEAD AUTHOR 

Fred Eames, Hunton & Williams 

CONTRIBUTING AUTHORS 

Janet Gellici, National Coal Council 

Mark Menezes, Hunton & Williams 

Eric Hutchins, Hunton & Williams 

CONTRIBUTING ADVISORS 

Shannon Angielski, CURC 

Shannon Banaga, Tampa Electric 

Carl Bozzuto, ALSTOM Inc. 

Dr. Frank Burke, Consultant 

Joe Divoky, Babcock & Wilcox 

Bill Elliott, Bechtel 

Dave Frederick, FirstEnergy 

Nina French, Clean Coal Solutions 

John Kennedy, Dynegy 

Jason Makansi, Pearl Street Inc. 

larry Monroe, Southern Company 

Karen Obenshain, EEl 

Deck Slone, Arch Coal 

Pamela Tomski, Global CCS Institute 

Matt Usher, American Electric Power 

Steve Winberg, Battelle 
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National Coal Council-leveling the Playing Field 

lEAD 

Richard Guerard, Hunton & Williams 

SCOP!NG TEAM MEMBERS 

Not noted elsewhere for their contributions 

Brad Crabtree, Great Plains Institute Sharon Sjostrom, Clean Coal Solutions 

David Flannery, Steptoe Johnson Rick Smith, Ameren 

Raj Gaikwad, Sargent & Lundy Scott Tee!, Southern Company 

Revis James, EPRI liam McHugh, World Coal Association 

Holly Krutka, Shenhua Group Ken Nemeth, SSEB 

Nancy Mohn, ALSTOM Mark Riedy, Kilpatrick Townsend 

Massood Ramezan, LTI Chris Ungate, Sargent & Lundy 

Dan Roling, NOVADX Ventures 

Robert 0. Agbede, Chester Engineers 

Sy Ali, Clean Energy Consulting 

Shannon Angielski, CURC 

COAl 

Richard Bajura, West Virginia University 

Shannon Banaga, Tampa Electric 

Janos M. Beer, Massachusetts Institute of 

Technology 

Jacqueline F. Bird, JFBird Enterprises 

lisa Bradley, Haley & Aldrich 

F. William Brownell, Esq., Hunton & Williams 

Wanda Burget, Norwest Corporation 

Dr. Frank Burke, Consultant 

Brad Crabtree, Great Plains Institute 

Christopher Curfman, Caterpillar Global Mining 

Division 

Jack Daly, Sargent & Lundy 

Joe Divoky, Babcock & Wilcox 

Ted Doheny, Joy Global, Inc. 

Michael D. Durham, Soap Creek Energy 

John W. Eaves, Arch Coal, Inc. 

George Ellis, Pennsylvania Coal Association 

Alex G. Fassbender, Ecovia Corporation 

Paul J. Feldman, Midwest ISO 

John s. Fischer, Breakthrough Energy, LLC 

David Flannery, Steptoe & Johnson PLLC 

COMMITTEE 

Mark Fraley, firstEnergy Solutions Corp 

Clark D. Harrison, CH2M 

William Hoback, Southern Illinois Univ. 

Clarence Joseph Hopf, Talen Energy 

Marty Irwin, PQR Energy 

Revis James, EPRI 

Michael Karmis, Virginia Tech 

Michael Kennedy, KY State Dept. Energy Dev. 

Norman Kettenbauer, GenPower Services 

John T. long, Connemara ltd. 

Richard P. lopriore, PSEG FossilllC 

Jason Makansi, Pearl Street, Inc. 

George McClellan, Clean Coal Solutions 

Nancy Mohn, ALSTOM 

Betsy Monseu, American Coal Council 

Ram G. Narula 

Kenneth J. Nemeth, Southern States Energy Board 

Jerry J. Oliver, Global Tech Management Services 

Fredrick D. Palmer, Peabody Energy (retired) 

Robert M. Purgert, Energy Industries of Ohio 

Dawn Santoianni, Tau Technical Communications 

Mark Schoenfield, Jupiter Oxygen Corporation 

Deck Slone, Arch Coal 

Matt Usher, American Electric Power 

Jeff Wallace, Southern Company (retired) 

Gregory A. Workman, Dominion Resources 
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National Coal Council leveling the Playing Field 

lEVEliNG THE PlA VING FIElD 

Policy Parity for Carbon Capture and Storage Technologies 

Table of Contents 

A. Executive Summary • . • • • • . • • . . . . • . • • . • . . • • . • • • . . . • . . . • . • . • • • • • • 1 

8. The Need for Carbon Capture and Storage Technologies •••...••..•••• 5 

1. Fossil Fuels Dominate in a Growing World, Today and Tomorrow 

2. The Need for C02 Emissions Reduction Technologies 

C. The Importance of Policy Parity 

for Carbon Capture and Storage Technologies . . . • . . . • • • . . • • • • • • • • • 13 

1. Defining Parity 

2. The Importance of Parity 

3. Parity and a level Playing Field 

4. Immaturity of CCS 

5. Unique Challenges Associated with CCS Technology Deployment 

D. The Power of Incentives and Policies •.••.••••..••••.•••.••...•••• 18 

1. Policy Dis-parity Between CCS and Other low-Carbon Energy Resources 

2. Existing Incentives for Renewables 

3. The Difference Between Renewables and CCS-Equipped Facilities 

E. The Playing Field for Carbon Capture and Storage Technologies .•...• 26 

1. Building Success 

2. The Cost Challenge Facing CCS Projects 

3. Existing CCS and Clean Coal Incentives and Proposed Incentives 

F. Recommendations ......•.............••••.••.••••.•..••.•.•. 32 

1. Financiallncentives 

2. Regulatory Improvements 

3. Research, Development and Demonstration 

4. Communication and Collaboration 

G. Appendices ...•...•••.•••.............•.••••••••••.•••••••.• 37 

1. Abbreviations 

2. Federal CCS/CCUS Incentive Proposals Introduced in 2015 

3. Case Study: AEP John W. Turk USC Power Plant 

4. Commercial Project Financing and the Role of Incentives 

5. Case Study: Contracts for Differences 

6. Case Study: FutureGen 

7. Government Support and a Strong Business Case Energize Boundary Dam 
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lEVELING THE PlAYING FIELD 

Policy Parity for Carbon Capture and Storage Technologies 

A. Executive Summary 

Federal energy and environmental policy has severely tilted the energy playing field. Secretary 

Moniz has requested the National Coal Council (NCC) make recommendations to level the playing 

field for carbon capture and storage (CCS) and provide "policy parity." 

Existing incentives for CCS are simply too small to "bridge the chasm"- as the NCC put it earlier this 

year- between the cost and risk of promising but immature CCS technologies and other technology 

alternatives. While CCS is commercially deployed in some industrial sectors and technically 

demonstrated at electric power plants, power generation with CCS remains expensive today 

compared to other technologies such as natural gas combined cycle (NGCC) or heavily subsidized 

renewables. The U.S. Department of Energy (DOE) has stewarded a successful research and 

development program to spur early development of CCS technologies, but without sufficient 

government support and incentives, commercial CCS deployment has lagged. 

Absent commercial-scale deployment, developers have no history to understand technical risks, 

frequency and duration of down time, and other critical factors that become known only with 

operation. Today, the world's first and only operating commercial-scale power plant with CCS has 

successfully achieved a capture rate of 80% of the plant's carbon dioxide {C02), but has been unable 

to maintain that level of performance and has been operational just 40% of the time because of 

technical complications. 1 With broad deployment, technological experience and confidence will rise, 

and costs will decline. Policy parity is essential to this progress. 

Coal and other fossil fuel use will keep rising globally as the world adds, per the United Nations, 

three billion more people to cities in the next 40-50 years. 2 To achieve climate goals and address 

fossil emissions, the world must have CCS.3 Commercializing CCS requires a level playing field. 

Cross-functional experts within the NCC's working groups have rigorously assessed the incentives 

and policies needed to level the playing field. There is consensus among them that the 

recommendations in this report will bring needed advances to development and deployment of CCS 

technologies. 

Other clean technologies have benefitted from substantial government support. In 1992 when 

Congress enacted the Section 45 renewable energy tax credit, the United States had less than 2,000 

megawatts {MW) of installed wind generating capacity.4 Today there are 69,471 MW of installed 

wind capacity.5 Wind energy prices have dropped from more than $50 per-megawatt-hour (/MWh) 

in the late 1990s to less than half that cost in 2014. 6 The industry credits government policy for its 

success: "With a two-thirds reduction in the cost of wind energy over the last six years, the 

renewable production tax credit (PTC) is on track to achieving its goal of a vibrant, self-sustaining 

wind industry." 7 
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In 2000, the U.S. had less than 4 MW of installed photovoltaic solar capacity, at an installed cost of 

nearly $10 per watt (/W). 8 In 2013, the U.S. had 6,000 MW of installed photovoltaic solar capacity at 

an average installed cost of roughly $2.75/W.9 Today there is more than 22,700 MW of solar 

generating capacity overall. 10 The industry touts 2015 as a "record-breaking" year in which more 

than 40% of all new capacity additions are solar. 11 As with wind energy, the industry credits 

government policy for its success: "Since the implementation of the investment tax credit {lTC) in 

2006, the cost to install solar has dropped by more than 73%." 12 

The policies that have driven these rapid deployment growth and cost reduction are a combination 

of Federal incentives and State renewable energy standards that mandate growing use of renewable 

energy. To satisfy the increasing State renewable energy generation requirements, an additional 

94,000 MW of renewable energy will need to be built by 2035. 

Figure A.l. Incentives for Renewable Electricity Generation 

Compared with Electricity Generation with CCS 
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National Coal Council- Leveling the Playing Field 

As Table A.l. shows, government support to launch CCS is not remotely comparable to renewables. 

A decade from today, it will be agreed that the incentives which proved effective in leveling the 

playing field for CCS technology deployment were those which enabled project financing to 

occur. These fall into two categories: those which provide up-front financial support for projects, 

and those which assure guaranteed revenue over the life of projects. 

In its January 2015 report, Fossil Forward: Revitalizing CCS- Bringing Scale and Speed to CCS 

Deployment, 16 the NCC recommended policy parity for CCS. In September, Secretary of Energy 

Moniz requested the NCC report on policy parity measures that would level the playing field for CCS. 

Among other specific recommendations, this report calls for the following: 

• Financial Incentives- Financial incentives for CCS must be substantially increased and 

broadened to include incentives available to other clean energy sources. Up-front incentives 

that reduce risk to capital should be emphasized, and designed with a recognition -as with 

wind and solar in the 1990s- that CCS is an immature technology with up-front risks and high 

initial capital costs. Operating incentives are important to assure a steady long-term revenue 

stream and lessen direct costs to consumers. Both types of incentives are needed and are 

central to "policy parity." Among the specific recommendations are the following: 

o Establish a "contracts for differences" (CFD) structure, one permitted under Federal 

law, to offer developers a menu of incentives to be provided by the government for 

competitively selected projects. The CFD structure may be the single most important 

mechanism to spur CCS development and deployment, but only if the incentives 

underlying it are sufficient. 

o Enhance DOE grants to increase the portion of the cost assumed by DOE to address 

the elevated capital costs of CCS projects. 

o Provide an electricity production tax credit consistent with that for renewables. 

o Provide for investment tax credits. 

o Guarantee purchase of electricity output with CCS to assure future revenue. 

o Establish a market set-aside for CCS, similar to State renewable energy requirements, 

implemented Federally through the existing structure of State programs. 
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National Coal Council- Leveling the Playing Field 

• Regulatory Improvements- A first-of-its-kind regulatory (FOAK) blueprint is needed to 

remove barriers to the construction and development of projects with CCS. This blueprint 

would be applicable to facilities for carbon capture (e.g., industrial facilities such as power 

stations), transportation, and injection. Given its charter and expertise, DOE is central to the 

development of this blueprint with sister agencies, which would include such elements as: 

o Streamlining siting and other permitting requirements for facilities necessary to a CCS 

project, including capture facilities, pipelines, and storage facilities. 

o Addressing uncertainty created by regulations, such as New Source Review {NSR) 

under the Clean Air Act, that might be triggered should retrofits or other expensive 

changes to existing power plants be made when installing carbon capture equipment. 

o Easing the new burden faced by enhanced oil recovery (EOR) operators under the 

111(d) existing power plant and 111(b) new power plant rules to facilitate the use of 

"regulated" COz. 

• Research Development & Demonstration -DOE must be a catalyst for additional 

commercial-scale demonstration projects, and such projects must commence 

immediately. The NCC remains firm in its belief that our national objective should be 5-10 

gigawatts (GW) of commercial-scale projects in operation by 2025. Projects must be in 

development stage promptly in order to achieve this goal. To be such a catalyst, DOE must 

identify for Congress a menu of incentives needed to mobilize project developers with 

funding mechanisms for commercial-scale CCS projects. Existing incentives have not been 

sufficient. 

• Communication and Collaboration- DOE needs to assure that U.S. and global policy makers 

and others firmly understand both that fossil fuels will be used in coming decades to a 

greater extent than today, and that there is a resulting need for CCS. DOE also should initiate 

international collaboration to support the prompt deployment of 5-10 GW of commercial 

scale demonstrations in addition to U.S. deployment. 
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National Coal Council Leveling the Playing Field 

B. The Need for Carbon Capture and Storage Technologies 

Meeting global COz emission reduction goals requires our expeditious deployment of COz 

technologies for fossil. That deployment will be advanced by incentives and policies to level the 

playing field for CCS. 

The commercial deployment of a suite of carbon reduction technologies is essential to worldwide 

efforts to reduce COz. These technologies: 

• Provide the most impactful opportunity to capture, use, and store a significant volume of C02 

from fossil fuels. The technologies can be used to reduce COz emissions from electric 

generation as well as from key industrial sectors, including cement production, iron and steel 

making, oil refining, and chemicals manufacturing. 

• Maintain electric reliability by providing baseload generation. Baseload power is the "always 

on" power that enables the grid to maintain voltage, frequency, and other attributes 

essential to reliable power supply. 

• Significantly reduce the costs of decarbonization. 17 Not including CCS as a key mitigation 

technology is projected to increase the overall costs of meeting C02 emissions goals by 70% 

to 138%. 18 

• Preserve the economic value of fossil fuel reserves and associated infrastructure while 

undertaking strong actions necessary to mitigate climate change. 19 

In January 2015, the NCC noted in its study Fossil Forward- Revitalizing CCS that in order to achieve 

CCS deployment at commercial scale, policy parity for CCS with other low carbon technologies and 

options is required. The NCC recommended to Secretary of Energy Moniz that DOE take a stronger 

position on the need for policy parity with respect to funding allocations. This white paper is 

presented in response to Secretary Moniz's follow-on request for recommendations on measures 

that can be undertaken by DOE to level the playing field for CCS and other low carbon coal 

technologies, providing market, operational, financial, and regulatory parity with other clean energy 

resources. 

Reducing carbon emissions from fossil fuels can have far more impact on atmospheric co, 

concentrations than building renewables because of the scale of emissions involved from fossil units 

and the direct C02 emissions reductions that result. By contrast, co, emissions avoided through new 

renewable generation capacity are constrained by renewables' smaller scale, the intermittency of 

wind and solar generation leading to lower capacity factors, the need for fossil load-following 

generation, and the fact that renewables displace existing grid power even in places where the 

generation mix is already less carbon intensive. Policy parity is critical to achieving carbon reduction 

objectives by moving more quickly toward the goal of deploying affordable, low carbon technologies. 

Advancing CCS and carbon management technologies should be viewed not as a subsidy for coal, but 

as a low carbon solution. 
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National Coal Council-leveling the Playing Field 

Policy initiatives must provide positive economic signals for CCS technology deployment. Policies 

that disadvantage fossil fuels have had a suppressing effect on deploying CCS technologies in a world 

that continues and will continue to rely on fossil energy resources for many years to come. 

1. Fossil Fuels Dominate in a Growing World, Todav and Tomorrow 

Globally, the vast majority of energy is supplied by fossil fuels. In 2014, 87% of global primary energy 

consumption was supplied by fossil fuels- primarily oil, followed by coal and natural gas.20 

According to the BP Statistical Review, "coal remains- by far- the most abundant fossil fuel by 

reserve/production ratio." 21 

The BP Energy Outlook 2035 notes that population growth and increases in income-per-person are 

the key drivers behind growing demand for energy. 22 By 2035, the world's population is projected 

to reach 8.7 billion, which means an additional1.6 billion people- five times the population of the 

United States- will need energy. Globally, gross domestic product (GDP)-per-person in 2035 is 

expected to be 75% higher than today, with China and India driving growth among non-OECD 

nations. By 2035, China and India will be the world's largest and third largest economies 

respectively, jointly accounting for about one-third of global population and GDP. 

Primary energy consumption is projected to increase by 37% between 2013 and 2035, with virtually 

all of the projected growth (96%) in the non-Organisation for Economic Co-operation and 

Development (OECD) nations. Power generation is expected to account for an ever-increasing share 

of that primary energy consumption, reflecting the global trend toward increased electrification. 

Globally, 44% of electricity is provided by coal. BP projects that coal will remain the dominant fuel 

for power generation worldwide in 2035, accounting for more than one-third of electricity 

production. 23 In the ASEAN region alone, according to the International Energy Agency's (lEA) recent 

special report on Southeast Asia, coal demand will triple between 2011 and 2035, with coal's share 

of power generation increasing to almost 50%. 24 
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Figure B.l. World Energy Consumption: OECD vs. non-OECD 

Another fossil fuel, natural gas, will also experience growth during this period. Global natural gas 

demand is expected to grow by 1.9% per year (2013-2035), driven by non-OECD demand of 2.5% per 

year. Increased usage by the power and industrial sectors will account for over 80% of total natural 

gas demand growth. 

The foregoing emphasizes that U.S. and international policy must be built on an appreciation that 

coal and other fossil fuels are an indispensable- not optional component of world energy supply 

for the foreseeable future. 

Since fossil fuels will remain the world's dominant source of primary energy for decades to come, if 

we are serious about addressing C02 emissions from fossil fuels we must support technological 

solutions. As Howard J. Herzog, Senior Research Engineer at the Massachusetts Institute of 

Technology so emphatically states it: "There are many uncertainties with respect to global climate 

change, but there is one thing about which I have no doubts: we will not solve climate change by 

running out of fossil fuels." 25 

2. The Need for C02 Emissions Reduction Technologies 

In light of the recent growth of fossil-fueled power plants in international markets, especially in nonOECD nations, achieving the goal of reducing C02 emissions will clearly require the deployment of 

C02 reduction technologies worldwide. Globally there are 510 coal power plant units under 

construction, with a further 1,874 planned; a total of 2,384 units. 
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National Coal Council Leveling the Playing Field 

China alone is bringing online an average of 500 MW of new coal capacity per week through 2030, an 

average of a new coal-fired plant every 7 to 10 days. The equivalent of the entire U.S. coal fleet was 

built between 2005-09- more than 500 coal plants of 600 MW. From 2010 to 2013, China added 

the equivalent of half the U.S. coal fleet, plus another 39 GW in 2014. China is predicted to add 

another U.S.-worth of coal capacity over the next decade, or the equivalent of one 600 MW plant 

every 10 days. By 2040, its coal-fired power fleet is expected to be 50% larger than it is today and 

these plants typically operate for 40 years or more. Today China consumes more than 4 billion tons 

of coal annually, compared to less than 1 billion tons in the U.S. and 600 million tons in the European 

Union (EU). 

China is not alone. BP's Energy Outlook 2035 predicts that C02 emissions from coal use will increase 

in India by 360 million tons by 2035. ASEAN countries also are expected to increase coal use 

significantly, far outstripping projected modest coal use reductions in the U.S. and Europe. 

1.50l} 

Source: World Coal Association 

These recently-built fossil fuel plants, which will continue to operate over a projected lifetime of 40-

60 years, as well as more mature plants still years away from retirement, constitute overwhelming 

evidence that CCS must be part of the path to reducing atmospheric C02 emissions. 

Here in the United States, C02 reduction technology deployment will similarly be necessary to 

achieve C02 emissions reduction policy goals. Coal provided fuel for 18.5% of total U.S. energy 

consumption and 43% of U.S. electric power generation in 2013. In 2014, the U.S. coal fleet totaled 

300 GW of capacity (28% of U.S. total generating capacity) and 1,586 million megawatt hours (MWh) 

of generation (39% of U.S. total). 26 
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Figure 8.3. Value of Existing Coal Fleet: Electricity Cost Savings 

Value of Existing Coal Fleet: Electricity Cost Savings 120 year total • $1400 Billion) 

100 

40 

30 

10 

2020 2025 2030 2035 

Source: National Coal Council Existing Coal Fleet Study 

In analyzing the value of the existing coal fleet, the NCC calculated the cost of replacing it with 

another form of generation. The NCC postulated that if all coal units were replaced by natural gas 

power plants, it would increase the cost of electricity by over $50 billion in 2020, rising to $90 billion 

per year in 2040. The $50 billion increase represents a nominal15% increase in the price of 

electricity which would reduce U.S. GDP and employment by about 1.5%. That 1.5% change could 

result in a $240 billion decline in GDP and a loss of 2 million jobs. 27 

Improving the efficiency of existing power plants plays an important role in meeting environmental 

objectives. Improving thermal efficiency can provide two important benefits: the reduction of fuel 

consumption, which lowers operating costs; and the reduction of emissions, including COz emissions. 

For example, C02 emissions requirements in the 111(d) existing power plant rule are based on 

substantial assumed improvements in power plant efficiency. However, the uncertainties created by 

NSR rules, their enforcement by the U.S. Environmental Protection Agency (EPA), and the prohibitive 

cost of administering N5R compliance have created strong disincentives to the widespread 

deployment of efficiency improvements. 
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National Coal Council- Leveling the Playing Field 

In conjunction with increasing the efficiency of the existing fleet, there is a growing need to add new 

baseload generation. Power generators are increasingly retiring coal plants in an effort to achieve 

compliance with environmental regulations. Much of the retiring coal capacity provides baseload 

generation, "always on" energy critical to maintaining electric reliability. Between 1998 and 2014, 

baseload generation represented 72% of total U.S. electric generation; coal generation accounted for 

59% of that baseload generation. 28 Base load facilities that can generate electricity on demand 65%· 

90% of the time, are needed to backup intermittent renewable sources that produce electricity only 

about 30% of the time. 

The U.S. Energy Information Administration (EIA) has projected a need for increased reliance on 

existing baseload coal units, rising to an average of around 74% capacity utilization in 2025 and 78% 

in 2040, versus a current average rate of around 60%. 29 As plants age, their capacity factors 

decrease. EIA's forecasts rely on coal infrastructure performing well at an unprecedented average 

age. Overestimation of coal unit capacity factors can result in reliability issues and underestimation 

of the need for replacement baseload capacity. In its analysis on this issue, DOE's National Energy 

Technology Laboratory (NETL) noted that this overestimation could be as large as 1,000 billion 

kilowatts hours (well over 100 GW capacity).30 NETL stated that, "as the fleet deteriorates, new 

baseload capacity will be needed to maintain this level of generation."31 

Baseload coal 

1,800 

1,600 

1,400 

1,200 

~ 1,000 

~ 800 

600 

400 

200 

0 

Figure B.4. Aging of Coal Baseload Assets 

when accounting fur coal-plant 

of new baseioad capacity 

Source: K. Kern, "Coal Baseload Asset Aging: Evaluating Impacts on Capacity Factors," 

washington D.C., 16 June 2015 
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A first step in advancing CCS is to provide financial incentives for investment in state-of-the-art high 

efficiency, low emission (HElE) coal power plants. 

Figure B.S. Potential Efficiency Improvements at Coal-Fired Power Plants 

llll 

llll 

Source: VGB PowerTech 2013, World Coal Association 

HELE technologies, including supercritical and ultra-supercritical/integrated gasification combined 

cycle plants, have significant potential to reduce C02 emissions through the deployment of more 

efficient coal power generation.32 Moving the current average global efficiency rate of coal-fueled 

power to supercriticallevels could deliver the equivalent environmental benefit of reducing India's 

C02 emissions to zero. The average efficiency of coal plants worldwide is 33%; state-of-the-art 

facilities have efficiency rates of 40%. Increasing the efficiency of coal power plants by 1% reduces 

C02 emissions by 2-3%. Many of these technologies are commercially available today and could cut 

2 gigatonnes of C02 emissions, equivalent to India's annual COz emissions.33 In the future, these 

units also could be potential candidates for CCS retrofits. 

A diverse set of technologies will be required to meet international GHG emissions goals. In its 

technology road map assessment, the lEA estimated that CCS would provide about 14% of the 

cumulative needed emissions reductions by 2050. 34 It is also important to recognize that lEA's goal 

assumes very significant efficiency improvements and renewables growth. If either of these does 

not occur at the rates projected, it is most certain that fossil fuels will fill the remaining gap, 

furthering increasing the need for widespread global deployment of carbon reduction technologies. 
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National Coal Council -leveling the Playing Field 

Figure B. G. Potential Emissions Reductions: Generation and Efficiency Options 

The rapid, widespread deployment of carbon reduction technologies will pay significant dividends 

toward achieving global greenhouse gas (GHG) objectives. We get to rapid, widespread deployment 

by leveling the playing field for low carbon coal technologies. 

GHG objectives are a matter of government policy. If the international community wants fossilfueled facilities operating in the coming decades to reduce C02 emissions, adequate government 

funding support is required to develop the technologies. 
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National Coal Council Leveling the Playing Field 

C. The Importance of Policy Parity 

For Carbon Capture and Storage Technologies 

1. Defining Parity 

CCS needs policies recognizing it as a still immature, not commercially available carbon reduction 

technology. These policies need to account both for cost factors and still uncertain technical 

performance risk. 

In reviewing government programs below, we emphasize that two incentive programs might cost 

government the same amount, yet bear no comparison for "parity" sake. A $1 billion government 

incentive that buys market share for a mature technology said to be as cheap as competing sources35 

is not the same as a $1 billion incentive needed to deploy and test expensive, FOAK emerging 

technology at commercial scale. Intensified assistance is needed to develop immature CCS 

technologies into successful proven ones, much as policy makers provided for renewables in the 

1990s. CCS will need continued assistance for years thereafter, because of the need for parity, if 

fossil with CCS is required to compete with mature subsidized technologies. 36 

2. The Importance of Parity 

Policy parity is important to meeting the diverse set of U.S. energy policy objectives. Those 

objectives have consistently focused on providing a reliable, secure, and low-cost supply of energy, 

and in recent years have increasingly directed energy production and consumption toward 

environmental objectives. 

CCS is essential to meeting those environmental objectives. Policy parity for CCS will have the added 

benefit of ensuring that we preserve other critical features of our energy system -such as fuel 

diversity and reliability- while we fulfill our nation's environmental obligations. 

• Reliability is priority one. Reliable power is not just a matter of convenience. Electric service 

must be reliable to ensure the health and safety of our nation's citizens. Diversity enhances 

reliability. 

• A diverse source of electricity provides an insurance policy against operational malfunctions 

and security breaches. 

• Diversity also provides a hedge against monopolistic or volatile pricing of any one source of 

power, which is why utilities, regulators and customers advocate for diversity. 

• Baseload sources are especially critical to maintaining a diverse generation portfolio that can 

meet environmental performance goals. The value and operating ability of intermittent 

renewables is greatly diminished without the backstop support of reliable "always on" 

generation. 
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Coal additionally provides enhanced energy security and reliability by virtue of its on-site storage 

capability, ability to be transported by various means (rail, barge and truck), and its widespread 

availability throughout the U.S. The value of diversity was notably highlighted during JanuaryFebruary 2014 when the U.S. was swept with a series of cold weather events that tested the integrity 

of electricity supply. 37 Wind produced only 4.7% of the nation's power during this time, while solar 

produced less than 0.2%. Nuclear provided only 5% of incremental year-over-year generation and 

hydroelectric output declined 13%. Natural gas supplies faltered and prices soared. In New England 

electric utilities paid more than $17.00 per million Btu for gas, while the average for the U.S. was 

$7.44 per million Btu, compared with normal seasonal prices of $4.41. Coal averaged $2.32 per 

million Btu. During the winter of 2014, coal provided 92% of the incremental increase in demand 

versus 2013. 

Figure C.l. Coal's Cornerstone Role in Times of Challenge 

tOO-t;, 

Portion of Increase in U.S. Electricity Generation, by Fuel 

Jan-Feb 2014 versus Jan-Feb 2013 

(Source Data: USDOE/EIA Electric Power Mgntbly) 

1111 Coal Oil Nuclear Renew Other 

Source: National Coal Council, Existing Coal Fleet Study, May 2014 

Leveling the playing field in an era of increasing concern about global climate change starts with the 

policy imperative of recognizing that coal will continue to be a major source of electricity in the U.S. 

and worldwide for decades to come. Parity for low-carbon coal technologies is needed to: 

• Facilitate diversity of the U.S. generation portfolio. 

• Advance the use of COz for EOR, providing a fully commercial, safe, and permanent path for 

COz storage, as well as a secure and less-carbon intensive domestic source of petroleum. 
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• lncent the deployment of CCS technologies for use by all fossil fuels in power generation and 

industrial applications. 

• Encourage the deployment of polygeneration and coal conversion facilities that domestically 

produce transportation fuels, chemicals, fertilizers, and other commodities. 

• Advance environmental performance of CCS while reducing the cost of electricity by 40% 

compared with new coal power plants built with today's CCS technology. 38 

Ensure that advanced baseload coal plants with CCS are available once existing baseload units 

are retired. 

• Support compliance with environmental objectives for COz reductions from existing and new 

power plants. 

3. Parity and a Level Playing Field 

CCS is the only technology that can substantially reduce C02emissions from "always on" base load 

power generation from secure fossil resources, domestically and internationally. It is also the only 

technology with applicability to the existing electric generating fleet as well as industrial sources, 

addressing both international emission goals and the imperative of electric reliability. There can be 

no true parity with a one-of-a-kind technology. 

The policy need at issue is to catalyze the rapid deployment of CCS to facilitate !ow-carbon fossilfueled generation. For the purposes of discussion, we will discuss parity for CCS in comparison with 

other low-carbon energy resources- renewables- whose successful and rapidly increasing 

deployment in recent years is attributable to policy intervention. 

A metaphorical playing field is said to be level if no external interferences affect the ability of the 

players to compete fairly. Policies that disproportionately advantage one resource and erect hurdles 

for others impede our nation's economic and environmental objectives while imposing undue 

hardship on our citizens. Incentives for renewables will persist. CCS, which has greater carbon 

reduction significance but is not yet commercially available in the power sector, requires additional 

policy support in order to level the playing field. 

4. Immaturity of CCS 

Policymakers justify incentives on the basis that a favored technology has not yet reached maturity. 

Many incentives for renewables are quite recent, being employed well after those technologies 

achieved maturity and became commercially available. Tax credits extended to the wind and solar 

industries in the U.S. were intended to promote the installation of these technologies by buying 

down the cost of market penetration. Yet, State and Federal policies already mandate markets for 

wind and solar, and tax incentives subsidized compliance with those mandates. 
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By comparison, many carbon reduction technologies, including CCS, are in their early stages of 

development and are highly complex in nature, entailing significant technical and financial risk for 

developers and investors. The risk profiles of building a 10 MW photovoltaic facility versus a 500 

MW supercritical coal power plant with CCS are significantly different. CCS systems entail much 

higher cost, have not been demonstrated on commercial scale in the power sector, and bind power 

production with back-end (i.e., transportation and storage) processes that likely will be beyond the 

generator's fence line and control. These and other challenges unique to CCS support the need for 

policy incentives, which if properly designed will result in C02 emission reductions, even as the use of 

fossil fuels increases. 

Figure C.2. Energy Technology Development Spectrum to Commercialize Technology 

Scale 

Source: National Coal Council, Fossil Forward Study 

Cart-before-horse policies that appear to be mandating CCS technologies (i.e., EPA's 111{d} existing 

power plant and lll(b) new power plant rules) will not incent CCS development or deployment. 

People will turn instead to mature alternatives. CCS needs policies recognizing it as a still immature, 

not commercially available carbon reduction technology. These policies need to account both for 

cost factors and still uncertain technical performance risk. 
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5. Unique Challenges with Carbon Capture and Storage Technology Deployment 

Development and deployment of CCS technologies present numerous unique challenges as detailed 

in the NCC's January 2015 report for Secretary Moniz, Fossil Forward- Revitalizing CCS. 

• Capital and operating costs for projects with CCS are more expensive than conventional 

technologies and carry great technological and commercial risk. Project risks include 

financing, permitting, public acceptance, cost overruns, schedule delays, performance, 

environmental compliance, operational flexibility, storage, and long-term liability. 

• Pioneering FOAK projects typically include a more rigorous investment due diligence process 

that is conducted during the front end engineering and design study and final investment 

decision stages, which can significantly add time and complexity to project schedules. 

• The main challenges for power generation with CCS include high cost (e.g., capital and 

operating costs, which influence project financing), large scale integration, access to suitable 

storage sites and high energy requirements (called the "energy penalty") to run the capture 

unit, including C02 compression. 

• Power plants or polygene ration facilities operating in deregulated electricity markets must 

account for additional time and complexity of negotiating power purchase agreements (PPA) 

and other offtake contracts (e.g., C02, urea). 

• Unlike earlier DOE-funded clean coal projects that demonstrated technologies such as SOx or 

mercury control, the central technologies being demonstrated for CCS are not ancillary to 

power plant operation and must be fully integrated to achieve reasonable cost and 

performance. 

• The technical risk of earlier DOE-funding demonstrations of environmental control 

technologies was not as great. With integrated CCS demonstrations, the central technologies 

must operate in order for the plant to function and to generate revenue for commercial 

operation. Thus, the developer has both a technological risk and a financial risk. 

Acknowledging the unique attributes of the various energy resources and their associated unique 

challenges can help guide the crafting of policies and incentives that maximize beneficial use of our 

nation's fossil, nuclear, and renewable resources. An appreciation of the policy dis-parities among 

energy resources is also instructive. 
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D. The Power of Incentives and Policies 

1. Policy Dis-parity Between CCS and Other low-Carbon Energy Resources 

Policy parity for CCS must be measured against other low-carbon energy resources. Earlier this year, 

EIA produced a report valuing subsidies and incentives provided to various forms of energy. 39 That 

report evaluated those subsidies targeted at energy, provided by the Federal government, and with 

an identifiable Federal budget impact were included. The report did not evaluate the impact of all 

subsidies. For example, the value of State renewable electricity mandates, which mandate that a 

percentage of electricity sold be produced from renewable sources, were not part of the study. 

The EIA report shows the single largest recipient category of Federal energy subsidies is, by far, 

renewables. Confining the discussion to electricity subsidies, where renewables and coal compete 

(i.e., screening out subsidies for vehicle fuels), in 2013 renewables received more than 12 times the 

subsidies as received for coal- $13.227 billion for renewables, and just $1.085 billion for coal. EIA 

reported that renewables received 72% of total subsidies while coal received just 6%. Conversely, 

support for renewables (i.e., solar, wind, biomass, geothermal, and hydro) has increased from 14.9% 

in 2007 vs. 72% in 2013. Support for wind alone increased from 10.7% (2007) to 37% (2013); support 

for solar alone increased from 0.2% (2007) to 27% {2013). Coal's share of support has declined 

significantly from 12.7% in 2007 to 6% in 2013. 

Even these numbers do not accurately capture the extent of the dis-parity between Federal support 

for renewables and coal. Only $40 million of the total for coal went to a direct credit for production 

of electricity, and then only for coal produced from refined coal or Indian coal facilities. At the same 

time, renewable electricity received a direct production tax credit of $1.63 billion, more than 40 

times the support provided to coal. 

Moreover, the subsidy for electricity from renewables is so large that it has enabled renewable 

energy producers to sell into energy markets at a negative price, which in deregulated markets can 

have the effect of reducing market prices for non-subsidized fuels- i.e., fossil and nuclear. 

In March 2015, the Congressional Research Service {CRS) released a report assessing the value of 

energy tax credits for various fuel resources. 4° CRS notes that in 2013, the value of Federal taxrelated support for the energy sector was estimated to be $23.3 billion, of which $13.4 billion 

(57.4%) supports renewable energy and $4.8 billion (20.4%) supports fossil fuels. In 2014, tax 

incentives for renewables constituted an estimated 53% of the estimated total revenue loss 

associated with energy tax provisions; revenue losses associated with fossil fuels-related tax 

incentives were 27%. The CRS report shows that in both years the investment tax credit for clean 

coal facilities did not exceed $200 million. 
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Figure 0.1. Public Policy Drives Investment 

Clean energy investment* between 

2004-2013 (USD): 

Source: Carbon Capture and Storage: Perspective from the lEA 

Eilina Levina, Sydney Australia, September 2, 2014 

The CRS report also notes, "While the cost of tax incentives for renewables has exceeded the cost of 

incentives for fossil fuels in recent years, the majority of energy produced in the United States 

continues to be derived from fossil fuels." In 2013, fossil fuels produced 78.5% of U.S. primary 

energy while renewables produced 11.4% and nuclear 10.1%. 

Financial support outside typical funding mechanisms for energy has also favored renewables over 

other fuel sources. Funds for renewable projects under the American Recovery and Reinvestment 

Act (ARRA) were $20 billion versus $3.4 billion for coal. 
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Figure 0.2. Subsidies for Renewable Project Deployment in ARRA 2009 

$20.0 

$18.0 

Jti $12.0 '6 

5 $1(U) 

~ v; st!JJ 

= 

12.0 

wBiomass 

• Hydro,ol:her 

mGe:o 

Solar 

Wfnd 

Sep '11 Mar'12 Jul'12 Mar, '1J Nov. '13 

Treas:wy Reporting Date 

Treasury Grants (ARRA Section 1603), 2009-2013 

Source: National Coal Council Fossil Forward Study 

In addition to financial support, renewables have benefited significantly from regulatory mandates 

creating a guaranteed market for wind, solar, biomass and other alternatives to fossil and nuclear 

power. A Renewable Electricity Standard (RES) obligates utilities to produce a specified percentage 

of their electricity from renewable energy sources. The Public Utility Regulatory Policies Act (PURPA) 

mandates the purchase of renewable energy from qualifying facilities (QFs) of 20 MW or less. Taken 

together, Federal production tax credits and State RESs have successfully and quickly spurred the 

growth of renewable energy in the U.S. It is clear from the graphic that the combination of policy 

and financial incentives are effective tools that can drive scale and speed in energy technology 

deployment. Applying similar types of initiatives to the deployment of carbon reduction 

technologies for fossil fuels can be expected to yield equally impressive production results with even 

greater COz emissions reduction benefits. Policy drove scale and speed for wind; to meet policy 

objectives, policy needs to do the same for CCS. 

The interaction of renewables subsidies, particularly the Section 45 PTC, and market structures not 

only have provided revenue to renewables, but have reduced revenue to fossil and other generators, 

many of whom have left the market in recent years. 41 "[Midwest Independent System Operator's] 

[independent market monitor (IMM)] reports that in 2011 wind power generation set the wholesale 

price of electricity during certain times and in certain locations, at an average price of negative $20 

per MWh. The IMM attributes this negatively set wind price to the availability of Federal production 

tax credit incentives. However, negative price offers may also be incented by the opportunity of 

wind power projects to sell renewable energy credits (RECs) to entities in order to comply with State 

RES policies." 42 In P JM, "[t]he IMM reports that an average of 935.5 MW, out of approximately 

5,300 MW, of wind resources were offered at a negative price to PJM's real-time market in 2011."43 
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Figure 0.3. U.S. Wind Industry: Incentives & Growth 

Additional points of disparity between coal and renewables are evident in program funding within 

DOE. DOE's CCS R&D Program was launched in 1997 with $1 million in funding. Today, DOE's CCS 

R&D program has grown to a $200+ million annual program with a portfolio of nearly 200 projects 

across the CCS chain in varying stages of development. As a point of contrast, the DOE Office of 

Energy Efficiency and Renewable Energy has a 2014 budget of $1.9 billion, of which $775 million is in 

direct support of renewable energy projects. 

To date, DOE's Loan Guarantee Program has issued more than $34 billion in "conditional 

commitments" in the form of either direct loans or loan guarantees, including $8.3 billion for a 

nuclear plant, $8.5 billion for automotive manufacturing and the remainder mostly to wind and solar 

projects. No advanced fossil projects currently have a loan guarantee. For the wind and solar loans, 

the mandated "subsidy cost"- the expected long-term liability cost to the Federal government that 

must be paid by the borrower or via congressional appropriation- was covered by the Federal 

government under the loan Guarantee Program. This "coverage" is not available for CCS projects. 

A commitment to leveling the playing field from these and other such dis-parities will significantly 

advance the quick and cost-effective deployment of low carbon coal technologies. 
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2. Existing Incentives for Renewables 

Below is a list of the primary incentives that have encouraged growth of renewable energy 

production. The scope of this report is not to include every policy- Federal, State and local- to 

promote renewables, but only those most relevant to recommendations for policy parity. 

• Production Tax Credit (PTC)- Section 45 of the Internal Revenue Code provides a tax credit 

of l.SC/kWh for energy produced from qualified energy resources. The credit is indexed to 

inflation and currently stands at 2.3C per-kilowatt-hour (/kWh), or $23/MWh. The credit is 

received for energy produced from a qualified facility for a period of 10 years after it is placed 

in service. First enacted as Section 1212 of the Energy Policy Act of 1992, this credit was set 

to expire on July 1, 1999. However, Congress has extended the credit nine times since its 

original enactment. Congress is again debating extension of the credit, which expired at the 

end of 2014, and some have called to make the credit permanent. Eligible energy resources 

include, among others, wind, solar, geothermal, biomass, incremental hydropower, and wave 

and tidal energy.44 Wind, closed-loop biomass, geothermal, and certain other facilities 

receive the full 2.3¢/kWh credit. Others, including open-loop biomass, landfill gas, 

hydropower, and wave and tidal energy receive one-half of the full credit, rounded up to the 

nearest tenth-of-cent to 1.2¢/kWh. The American Wind Energy Association testified in 2013 

that "without the PTC," installation of wind generation and related economic benefits and 

investment "would not have occurred." 45 

• Investment Tax Credit {lTC)- Section 48 of the Internal Revenue Code provides up to a 30% 

tax credit for qualified energy property. It is considered the "solar tax credit" because solar is 

one of the few types of energy property to which the full credit applies. The rapid expansion 

of solar installations that has occurred since enactment of the lTC, has been attributed to the 

credit.46 Other qualified energy property receives a 10% credit. 

Cash Payment- ARRA Section 1603 allowed taxpayers to obtain a cash payment instead of 

receiving either the PTC or lTC. The facilities had to be placed in service in 2009, 2010 or 

2011, unless they commenced construction during that time and placed the facility in service 

later (date dependent upon type of facility). 

• loan Guarantees- Title XVII of the Energy Policy Act of 2005 (EPAct '05) established the 

Section 1703 loan guarantee program for various types of energy projects that "avoid, 

reduce, or sequester air pollutants or anthropogenic emissions of greenhouse gases," 

including renewables, "advanced fossil energy technology," and "carbon capture and 

sequestration practices and technologies" among others. No loan guarantees have been 

made to fossil projects under the Section 1703 program. By contrast, loan guarantees under 

Section 1703 and 1705 (described below) have been issued for 18 renewable electricity 

production facilities totaling more than $12.8 billion, and for renewable electricity 

manufacturing facilities totaling nearly $1.1 billionY As part of the ARRA in 2009, Congress 

created the Section 1705 loan guarantee program for certain renewables, under which 

recipients would not be required to pay the credit subsidy cost of the guarantee, further 

lessening their cost. 
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• Mandatory Purchase Requirement- Under PURPA enacted by Congress to address the 

energy shortage in the '70s, utilities are required to purchase power from "qualified facilities" 

(QFs). QFs can be cogeneration units, where power is used for an industrial purpose, or small 

power production facilities which are renewable projects of 80 MW or less. To address the 

overbuild of "PURPA machines" which forced utilities to buy unneeded power from QFs at 

"avoided costs" typically at above market rates, Congress repealed the application of the 

mandatory purchase obligation if the U.S. Federal Energy Regulatory Commission (FER C) 

found that the QFs had access to competitive electricity markets. FERC has exempted most 

large QFs in the organized markets but continues to grant QF status to all renewable QFs of 

20 MW or less, regardless of access to markets. Furthermore, FERC allows large renewable 

QF projects, such as wind and solar, to be split up into 20 MW projects to be granted QF 

status requiring utilities to purchase the power produced whether needed or not at "avoided 

costs" typically higher than market rates. 

• Research and Development Funding- DOE budgets in recent years have provided 

substantially more money for renewables research and development than for clean fossil, 

particularly coal. The FY 2016 DOE budget request of $2.7 billion for the Office of Energy 

Efficiency and Renewable Energy is more than all of the other applied science budgets 

combined. The budget request for the entire Federal government detailed approximately 

$7.4 billion for clean energy programs, including more than $710 million to increase the use 

and reduce the costs of power from solar, wind, water and geothermal energy. By contrast, 

the FY 2016 budget request included $560 million for fossil energy R&D, with just $224 

million dedicated to CCS research. 

• Siting and Interconnection Preferences- Renewables also have benefited from special 

procedures for siting, interconnection, and other approvals necessary for a project to deliver 

energy to the market. FERC Order No. 792, for example, provides for fast track 

interconnection approvals for inverter-based generators (such as solar panels) of up to 5 

MW, if their capacity is no greater than the minimum load on the line to which they are 

connecting. 

• Clean Energy Credits- The Clean Energy Incentive Program in EPA's finallll{d) existing 

power plant rule provides extra emission reduction credits for wind and solar projects that 

begin generation by 2021. EPA will grant one additional credit per MWh of generation from 

eligible wind and solar projects. Other zero or low-emission projects are not eligible for this 

special credit, which is limited to a total of 300 million tons. At the current carbon credit 

prices in California and Regional Greenhouse Gas Initiative (RGGt), the value is $3.505 billion 

or $1.806 billion, respectively.48 Note that this benefit is being provided notwithstanding that 

renewables are already flourishing. 
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• State Renewable Energy Standards- Twenty-nine States plus the District of Columbia have 

binding portfolio standards mandating that a certain percentage of energy sold come from 

certain sources, virtually always renewable generation. They range from a 100% renewable 

energy mandate by 2045 recently enacted in Hawaii and a recently enacted 50% renewable 

energy mandates in California by 2030, to 10% mandates to be reached in 2015 in Texas, 

Michigan and Wisconsin. According to a 2013 study by lawrence Berkeley National 

laboratory (LBNL) (which would not reflect recent increases like those in Hawaii and 

California), 94 GW of new renewable energy is required by 2035 to meet State renewable 

energy requirements- 3-5 GW per year of additions through 2020 and 2-3 GW per year 

through 2035. 49 The LBNL study found these policies drove the addition of 6-13 GW of 

renewable energy per year in every year but one since 2008. Of this amount, 88% of the 

capacity additions from 1998-2012 were wind energy. 50 The study also found that 67% of 

non-hydro renewable capacity additions between 1998-2012 were in States with renewable 

energy requirements. 51 The true percentage of renewables constructed to satisfy portfolio 

standards may be substantially higher, as most States do not require the energy to be 

sourced in-State. 

• Net Metering- A number of States provide for "net metering" under which a utility customer 

can receive credit on their bill for energy they produce and sell to the grid. However, the 

credit can amount to more than the value of the energy. Some States provide, for example, 

that net metering customers be paid the delivered electricity price for each kWh they sell to 

the grid i.e., if the delivered price is $0.10/kWh, the customer is paid that amount even 

though that price includes generation, transmission and distribution. A 2013 California Public 

Utilities Commission report found the State's net metering program would cost the State 

$1.1 billion per year by 2020.s2 

• Battery Storage Incentives- Because the sun, wind, and other non-hydro renewable 

resources do not provide a constant source of energy, renewable-based generation is 

inherently intermittent. Subsidies are now even being provided for large-scale batteries to 

store the subsidized electricity generated from renewable resources. These "subsidizedsubsidies" come in the form of subsidies to build the batteries and even State funding to 

build the factories to make the batteries. 53 

House and Senate legislation introduced in 2015 has proposed additional Federal assistance for 

renewables. 54 
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3. The Difference Between Renewables and CCS-Eguipped Facilities 

In addition to the tax incentives provided to renewables, the current policy landscape discourages 

the construction of CCS-equipped projects by failing to address the investment costs required of 

deploying the technology at power and industrial facilities. These costs, coupled with the increased 

levelized cost of electricity (LCOE} for new-build power plants with CCS, reveal how an even wider 

dis-parity exists than might otherwise be assumed. Although LCOE is one means of measuring the 

overall competitiveness of different generating technologies, its use in this comparison does not take 

into account all aspects of projected utilization rates and capacity values, two elements that further 

favor the construction of coal and other baseload resources. 

According to information disseminated in conjunction with the EIA's Annual Energy Outlook, the 

LCOE values for incremental wind capacity coming online in 2020 ranges from $65.6/MWh to 

$81.6/MWh, depending on the quality of the resource. 55 Although these LCOE values compare 

favorably to NGCC facilities, the former is a non-dispatchable technology, one with just a 36% 

capacity factor. This means almost three times more capacity is needed when building wind as 

opposed to either conventional coal, advanced coal equipped with CCS, NGCC or NGCC equipped 

with CCS. However, equipping a conventional coal or NGCC plant with CC5 technology carries 

significant costs. 

Recognizing that LCOE values for coal-fueled power plants equipped with CCS change depending on 

the type of power plant (i.e., subcritical or supercritical), coal rank, and the type of technology 

deployed, the current cost of adding carbon capture virtually prohibits widespread adoption at new 

and existing facilities. The Global CCS Institute recently estimated LCOE values of coal with CCS at 

$115-160/MWh, some 35-85% higher than a coal plant without CCS.56 Data prepared by EIA 

estimates an LCOE value of $144/MWh for "advanced coal" equipped with CC5. Conventional and 

advanced combustion natural gas turbines also experience significant price increases once CCS is 

added, $141.5/MWh and $113.5/MWh, respectively." 
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E. The Playing Field for Carbon Capture and Storage Technologies 

1. Building Success 

The NCC and others have performed gap analyses to define the difference between the current 

trajectory of CCS and what is needed to propel its progress. Fossil Forward reported that substantial 

additional financial support is needed. It described desired endpoints for each link in the CCUS chain 

-capture, transportation, and storage/utilization -then provided recommendations to meet those 

endpoints. 

Fossil Forward described the desired endpoint for COz capture as facilitating widespread deployment 

of CCS in the 2030s. In order for this to occur, COz capture must be ready for commercial 

deployment in the decade before. The benchmark for being commercially available used in the NCC 

report is for a technology to have operated reliably at full commercial scale for at least one year with 

reasonable cost and performance so it can be commercially insurable and financeable. Today the 

world has only one power plant with CCS operating at commercial scale. After one year of 

operation, it does not exhibit the reliable performance hoped. SaskPower's Boundary Dam Unit 3, 

retrofitted with carbon capture through the help of government incentives, is designed to achieve a 

capture rate of 99% of the plant's C02. The plant achieved a peak-performance capture rate of 

approximately 80% in June 2014, but since mid-January 2015 has achieved a best capture rate of 

65%. Furthermore, the plant has operated only 40% of the time in its first year because of technical 

complications. 58 

Reaching the desired benchmark should be the intended outcome of DOE's CCS program. Among 

others, the report made the following recommendations: 59 

• Have 5-10 GW of CCS demonstration projects operating in the U.S. by 2025. 

• Provide budget and have a plan to fund 25-50 MW of demonstrations of second generation 

C02 capture technologies in the U.S. by 2020. 

• Continue to "feed the pipeline" by sponsoring early stage R&D on transformational 

technologies. 

• DOE's program needs to address the risk that a CCS project developer may not timely find 

economic C02 storage. 

• There is a need for financing mechanisms beyond those currently available. 
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2. The Cost Challenge Facing CCS Projects 

The NCC reported that a next-of-a-kind (NOAK) plant using monoethanolamine scrubbing could 

expect to have increased capital cost of 67% over a conventional plant without CCS. The increased 

cost of electricity is estimated to be 63%. The estimated cost of capturing C02 is $58/ton, while the 

estimated cost of COz avoided is $78/ton. 

NETL's Office of Program Planning and Analysis issues costing methodologies it uses to estimate the 

costs of developing FOAK technologies into mature, commercially viable power plants (i.e., NOAK). 

NETL assesses the "learning curve" of various technologies necessary for power plants using CCS in 

determining the expected actual costs per unit output per facility. 

These costs are considerably higher when compared to the average cost of output of fossil power 

plants including costs of operations, maintenance, and fuel. In 2013, NETL, using 2007 dollars, 

estimated that the cost of learning to develop and install commercially operational super-critical 

pulverized coal plant with CCS would be $2,045.00/kW. By 2020, DOE predicts that Advanced Coal 

plants with CCS capable of dispatch to provide reliable, base load generation will cost $144.4/MWh. 

Clearly, these recommendations and findings suggest a need for substantial financial support. 

Figure E.l. Innovative Technology Risk and Cost 

2. Longerdeotterm 

Lower interest rate 

Source: Andrew Paterson, CCS Alliance 
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Costs of CCS can be offset by the sale of co-products. Southern Company's Kemper County facility, 

for example, will make and sell fertilizer from chemical streams resulting from the gasification 

process. It also has agreements to sell the COz to oil producers for enhanced oil recovery (EOR). 

These revenues are significant, but not nearly sufficient to cover the capital and operating costs 

associated with carbon capture. Market prices for COz for EOR in some areas have been above 

$25/ton.60 However, lower market prices for oil affect what oil producers can and will pay for 

industrial-sourced COz. A steady revenue stream is needed for financing industrial facilities with 

carbon capture. The Coal Utilization Research Council (CURC) has proposed a variable price support 

mechanism for the price of C02 pegged to the oil price, which would provide industrial COz 

producers with a steady COz income stream to make their capture projects financeable. 

An often-cited issue with COz-EOR is that the opportunities for its deployment are not currently 

geographically widespread enough to present a nearby opportunity for a coal fleet scattered widely 

across the country. However, the estimate of the COz-EOR opportunity has grown substantially as 

detailed in research that has emerged over the past three years. 61 

CURC and the Electric Power Research Institute (EPRI) publish a periodically updated Roadmap for 

Advanced Coal Technology, including CCS.62 The purpose of the Road map is to provide 

recommendations that will substantially drive down the cost and increase efficiencies of advanced 

coal technology, including CCS. 

The 2015 update re-examined technology development needs in light of new factors, such as 

persistent low natural gas prices, GHG regulations, and increasing renewable generation. The CURCEPRI Roadmap looked at what is needed to support development of transformational technologies 

that will deliver cost, efficiency, and environmental performance improvements, as well as the need 

for a large-scale pilot program to test technologies under real operating conditions before 

commercial-scale demonstration. The Road map identifies a need for increased Federal funding. In 

particular, it calls for 100% Federal financing for large pilot-scale testing of these new technologies. 

It also calls for the Federal government to fully fund a 50% cost share for commercial scale 

demonstration, a share which has not been met for any of the CCPI projects (the W.R. Parish project 

receiving the highest percentage at 16.7%).63 
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Figure E.2. Matching Incentives to Commercial Risk 

Source: Scully Capital 

DOE support and incentives to bridge the gap must be flexible to account for local differences in 

market structure, as well as local, technical, and financing vagaries. States are divided between 

those with traditional cost-of-service utility regulation, and those with deregulated markets. In areas 

with cost-of-service regulation, a utllity proposing construction of a new power plant would be 

required to undergo hearings before State utility regulators to determine whether the construction 

of a new facility is justified in light of the alternatives, and will be cost-effective. State regulators 

may take into account special benefits of a facility, such as its use of in-State resources and similar 

factors that may benefit the State and consumers. Regardless, rates charged to consumers to pay 

for the facility must be "just and reasonable." 

In deregulated market areas, no approval to build generation is required from rate regulators. 

Markets determine whether a new facility is cost-justified. Absent subsidies and mandates, such as 

those that apply for renewables, facilities that cannot recover their cost through rates earned in the 

market do not get built. In both regulated and deregulated market areas, CCS is in essence 

competing with new-build natural gas without CCS, a low cost option. CCS must be able to be cost 

competitive in both markets. 

Access to a variety of financing options, taking into account both regulated and deregulated market 

areas and other considerations, is a recommendation that has consistently emerged over the years 

from meetings on CCS financing, such as those hosted by the Carbon Sequestration leadership 

Forum. The rationale is quite simple. Incentives need to fit local circumstances. 
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3. Existing CCS and Clean Coal incentives and Proposed incentives 

CCS and clean coal technologies currently benefit from several Federal programs and some State 

programs to encourage development, demonstration, and deployment. While these programs could 

spur CCS development if revised, enhanced, and complemented with other incentives, they are not 

sufficient as is (which is evident from the lack of projects resulting from them, and in some cases 

even lack of bids to use the incentives). These programs provide far less support than policies 

supporting renewables. Below is a description of the main existing incentives for CCS technologies. 

• Research and Development- DOE's budget includes line items for both carbon capture and 

storage. This funding supports pilot-scale carbon capture projects as well as projects focused 

on storage infrastructure. However, funding for renewable research and development is 

regularly more than twice that spent on CCS. 

• Demonstration- EPAct '05 authorized the Clean Coal Power Initiative (CCPI} to "advance 

efficiency, performance, and cost competitiveness well beyond" commercial technologies."' 

In 2009 and 2010, DOE announced a Round Three of CCPI funding for 3 CCS power plant 

projects: Texas Clean Energy Project (TCEP), Hydrogen Energy California Project (HECA), and 

W.A. Parish Post-Combustion CCS Project65 However, neither TCEP nor HECA have begun 

construction, and their DOE funding has been removed or reduced. Indeed, as of 2013, only 

$228 million of the $1.04 billion obligated to CCPI Round Three had been spent. 66 Notably, 

CCS demonstration projects have not received an appropriation since 2009. 

• FutureGen 2.0- Utilizing $1 billion in funding made available from ARRA and additional 

funding from annual appropriations, the FutureGen 2.0 effort was announced on August 5, 

2010 to repower Unit 4 of the Meredosia Energy Center with oxycombustion technology and 

to capture and sequester approximately 1 million metric tons of COz per year. FutureGen has 

suspended operations. A case study of the project is included in Appendix 6. 

• loan Guarantees- EPAct '05 established a loan guarantee program for various types of 

energy projects that "avoid, reduce, or sequester air pollutants or anthropogenic emissions of 

greenhouse gases," including "advanced fossil energy technology" and "carbon capture and 

sequestration practices and technologies." In 2009 and again in 2013, DOE issued 

solicitations for coal-based power generation projects and advanced fossil energy technology 

with carbon capture. Although several applications were received, no clean coal project, or 

any fossil project, with our without CCS, has received any loan guarantee since EPAct '05 was 

enacted. 67 

• Investment Tax Credits- EPAct '05 established investment tax credits under new Sections 

48A and 48B of the Internal Revenue Code for qualifying advanced coal power projects and 

industrial gasification facilities. These credits provide a credit of up to 15% or 20% 

(depending on project type), but are limited in the amount of dollars that can be provided to 

all projects in total. Credits have been unallocated or forfeited due to inability to meet 

statutory requirements for the credits.68 
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• Carbon Sequestration Tax Credit- Section 45Q of the Internal Revenue Code provides a 

$10/ton credit for COz stored through enhanced oil or gas recovery, and a $20/ton credit for 

COz stored in other formations. The credit is limited to 75 million tons total of sequestered 

COz for all recipients. Due to restrictions in the credit (e.g., a requirement that the taxpayer 

both own the industrial facility from which the COz is captured, and inject the COz; lack of 

transferability of the credit), only slightly more than one-third of the credit {27,114,815 

metric tons) has been claimed since its enactment in 2008. 69 Virtually none of these credits 

went towards COz captured from electric generating facilities. 

• State Portfolio Standards- Five States- Utah, Michigan, Ohio, West Virginia, and 

Massachusetts- allow electricity generated using CCS to be included in their electricity 

portfolio standards.7° However, electricity generated using CCS has not been applied as part 

of any of these State's portfolio standards. 

Numerous incentives to promote CCS research, development, demonstration and deployment have 

been proposed in recent years, with the pace accelerating during 2015. Appendix 2 sets forth a list 

of Federal incentives proposed by the Obama Administration or Congress this year. 
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F. Recommendations 

The NCC recommends a significant ramping up of incentives to "bridge the chasm" for CCS and, per 

the Secretary's request, to provide policy parity. These recommendations will address the policy 

mismatch between actual and needed CCS technology funding, and between funding for CCS and 

other low-carbon energy resources. 

The recommendations provide a menu of financial support options that will provide the necessary 

support for CCS and constitute policy parity. As with incentives for other energy resources, it is not 

intended that all of these incentives will be available for each project. Several of the proposed 

incentives should be crafted as alternatives- much as with renewables the production tax credit, 

investment tax credit, and cash grant programs have operated as alternatives. 

No single proposed incentive should be viewed as a self-sufficient independent recommendation. A 

combination of support mechanisms spurred renewables development, and that is what is needed 

for CCS. If offering loan guarantees alone was sufficient to spur commercial CCS deployment, we 

would have more projects in development today. 

A key recommendation is to institute a "contracts for differences" or CFD structure, available for a 

limited number of CCS projects, under which projects would bid for financial support making use of a 

combination of the proposed incentives. This structure is in use in the United Kingdom, whose 

program is described in Appendix 5. By way of example, a CFD structure could provide a power plant 

contract recipient with a CCPI grant to reduce capital cost, provide a loan guarantee to reduce 

borrowing cost, and make use of tax credits to reduce the cost of electricity over time. Another 

applicant may prefer to request variable price support for electricity, as offered in the U.K, or 

variable price support for C02 sold from the facility, in place of other incentives. The CFD structure 

may be the single most important mechanism to spur CCS development and deployment, but only if 

the incentives underlying it are sufficient. 

Former Senate Energy & Natural Resources Committee Chairman Jeff Bingaman (D-NM) proposed 

legislation several years ago authorizing DOE to enter into up to 10 contracts for technical and 

financial support for CCS projects. We recommend providing the CFD structure for at least the first 

5-10 GW of projects with CCS on a competitive basis. This could include projects already in the CCPI 

program. While several projects received limited grants and underwent substantial planning, only 

two are under construction and none are complete. 

These options should be deployed in a manner to result in operating projects (particularly 

commercial demonstrations and large-scale pilots), support a diverse set of technologies in a variety 

of circumstances and locations, minimize Federal outlays, and minimize distortions of markets that 

have occurred from implementation of incentives for other low-carbon energy sources. 
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In its 2014 annual survey of power generators and technology developers, the Global CCS Institute 

found that the top three enablers for CCS projects were 1) access to direct subsidies, 2) access to 

viable C02 storage, and 3) offtake arrangements offering guaranteed prices.71 We include proposals 

for each of these below. As will be apparent, many of these recommendations require congressional 

enactments. Appendix 2 shows interest in Congress in supporting CCS, including recently among 

senior congressionalleaders. 72 

Financial Incentives 

• Contracts for Differences- DOE should provide for a CFD structure under which a limited 

number of projects -at a minimum the first 5-10 GW of output from facilities with CCS- can 

receive a combination of the incentives described below. 

• limited Guaranteed Purchase Agreements- In order to obtain financing, a limited number 

of pioneering facilities with CCS should receive a guarantee that their output will be 

purchased. This is key to the development of an immature technology with a yet uncertain 

risk profile and a potential for significantly lower cost. It also is a key element in parity, as 

renewables have benefited from PURPA mandatory purchase requirements. This incentive 

should be limited in scope to cover at least the first 10 GW of output from facilities with CCS, 

be designed to encourage geographically diverse projects, and minimize impacts on 

electricity markets. 

• Market Set Aside- True parity would entail a mandatory market set-aside, akin to State 

renewable energy requirements. As noted by LBNL, the vast majority of renewables 

construction has occurred in States with an active or impending RES. One mechanism to 

provide a market set aside is a "baseload allowance." Fossil technologies that deploy CCS or 

other immature carbon reducing technologies and meet a define carbon emissions rate while 

providing baseload power would be eligible for the credit. Given the importance of CCS to 

meeting climate goals, we recommend a Federal mechanism be explored to authorize a 

portion of any State-mandated RES to be met through use of qualifying low-carbon fossil 

baseload, similar to those in Utah, Michigan, Ohio, West Virginia, and Massachusetts. 

• Clean Energy Credits- Fossil projects with CCS should receive credit under applicable 

programs for 100% of C02 emissions avoided by deployment of CCS. Programs that currently 

allocate extra clean energy credits for renewables either should make the same credit 

available to fossil with CCS, or the extra crediting should be removed to assure parity. 
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• Tax Credits and Price Interventions- Guaranteed purchase agreements, and the ability to 

attract financing that accompanies it, is only part of the equation. Facilities will not be built 

by entities subject to traditional utility regulation if State utility commissions determine the 

cost is too high. In areas with EOR opportunity, incentives could involve price support for C02 

sales. Below are specific proposals: 

o Production Tax Credit- Policy makers should provide a tax credit for production of 

electricity with CCS equivalent to that for renewables in Section 45. Options for 

structuring the credit could include {a) applying the credit consistent with the lower 

available inflation-indexed rate in Section 45 (i.e., 1.2¢/kWh) for capture at a new 

facility that brings the rate of emissions to 1,400 lbs./MWh, increasing 

proportionately to 2.3C/kWh as the capture and storage rate increases toward 100%; 

or {b) applying the full 2.3¢/kWh credit to the number of kWh dispatched, multiplied 

by the capture percentage. 

o COz Price Stabilization- Establish a "variable price support" program for C02 

sequestration under which applicants would bid to DOE for financial support 

payments for C02, tied to the market price for oil (where EOR opportunities are 

available). This variable price support would be used under CFD agreements. 

o Electricity Price Stabilization- Establish a price support program for electricity under 

which applicants would bid to DOE for financial support for a limited number of 

projects. The support would be based on the delta between the amount needed to 

achieve a commercial rate of return and the amount that can be earned, in the case of 

regulated markets, at just and reasonable rates, or in the case of deregulated 

markets, at projected market rates. This variable price support would be used under 

CFD agreements. 

o Revise C02 Injection Credit- The Section 45Q tax credit should be revised as follows: 

Eliminate the requirement that the recipient both capture and inject the C02 

{which may not be the case, for example, with a power plant selling C02 to the 

oil field) 

Assure that injection that qualifies under existing verification mechanisms as 

sequestration is satisfactory to obtain the credit 

Provide for transferability of the credit between parties in the capture and 

injection chain of custody; and 

Increase the credit to $40/ton for beneficial reuse {e.g., EOR storage) and 

$60/ton for other geologic storage. 
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• Tax-Preferred Bonds- A variety of activities can be funded by tax-preferred and tax-exempt 

bonds. Renewable projects funded by local governments and electric cooperatives may issue 

Clean Renewable Energy Bonds under Section S4 of the Internal Revenue Code to finance 

clean energy projects (those which also are covered by the Section 45 tax credit). 

Approaches could include extending the Section 54 approach to CCS, or qualifying CCS 

projects for use of exempt facility bonds issued under Section 142. 

• Master limited Partnerships (MlPs}- Section 7704 of the Internal Revenue Code provides 

that business structures receiving at least 90% of their income from "qualifying income" can 

be treated as master limited partnerships for tax purposes; therefore, their income will be 

taxed only at the individual level, rather than both the corporate and individual level. 

Currently neither renewables nor low-carbon fossil technologies such as CCS qualify for this 

treatment. If renewables are made eligible for such treatment, parity requires that CCS also 

qualify. 73 

• loan Guarantees- As indicated above, DOE's loan guarantee program has helped 

renewables, but not CCS. Congress enacted a special $6 billion program to pay for the credit 

subsidy cost of renewables, another dis-parity with fossil deploying CCS. The loan guarantee 

program should be revised to provide opportunity for the same credit subsidy relief for fossil 

projects as has been provided to renewable projects under the Section 1705 program. 

Regulatory Improvements 

• Regulatory Blueprint- DOE must take the lead in developing a regulatory blueprint which 

removes barriers to the construction and development of projects with CCS. This blueprint 

would be applicable to facilities for carbon capture (e.g., industrial facilities such as power 

stations), transportation, and injection. Given its charter and expertise, DOE is central to the 

development of this blueprint with sister agencies, which would include such elements as 

addressing the specific regulatory barriers below. 

• Remove Injection Barriers- EPA's 111(d) existing power plant and 111(b) new power plant 

rules both provide that C02 from power plants regulated by the rule that is injected at oil and 

gas wells be reported under more stringent reporting rules than is currently required. Some 

C02 users have said this will discourage rather than encourage their use of C02 from these 

sources in the oilfield, and that associated regulatory obligations may conflict with State 

natural resource law. Federal policy should encourage and facilitate reuse of C02 from CCS 

operations, not discriminate against it. 
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National Coal Council- Leveling the Playing Field 

• New Source Review- Concerns have been raised that retrofits of existing power plants to 

install carbon capture could trigger NSR requirements of the Clean Air Act. Such retrofits 

would constitute a "physical change" at the facility, and some may argue this could result in a 

significant net emissions increase. If we are to reduce C02 emissions from existing facilities in 

the U.S., government policy must eliminate this uncertainty in order to encourage rather 

than discourage installation of C02 emission control equipment. 

• Infrastructure Siting- Federal policy makers should consider Federal eminent domain 

authority for the siting and construction of C02 pipelines, like the authority provided under 

the Natural Gas Act for natural gas pipelines could be provided. If a State does not have 

authority to provide for siting of a pipeline, or fails to act within a reasonable period, FERC 

should be available as a backstop siting and permitting authority. 

• Storage Siting- The NCC recommends that DOE identify and certify at least one reservoir 

which is capable of storing a minimum of 100 million tons of C02 at a cost of less than 

$10/ton in each of the seven regions covered by DOE's Regional Carbon Sequestration 

Partnership program. 

Research, Development and Demonstration 

• Align Research, Development, & Demonstration {RD&D) Funding With Other Fuels- DOE 

needs to increase substantially the budget for RO&D funding for CCS. The CURC-EPRI 

Roadmap is the industry's best-supported estimate of the funding needed for CCS RD&D. 

Even if fully funded, the CURC-EPRI Road map falls short of parity with renewables RD&D. The 

NCC recommends fully funding CCS RD&D at a minimum as recommended in the Road map. 

That would include funding an 80% Federal cost share for early stage RD&O, 100% Federal 

cost share for large-scale pilots, and a fully funded 50% cost share for commercial 

demonstrations.74 

Communication and Collaboration 

• Vigorously Explain Reality- First and foremost, DOE must be a tireless advocate in all venues 

for recognition that fossil fuels will be used in coming decades to a greater extent than today 

to fuel a more populous, developed, urban world. Those who deny these facts in the name of 

addressing climate change not only harm fossil fuels and ambitions for improved health and 

quality of life, but diminish the likelihood of meaningful C02 emission reductions. 

• Initiate Projects Immediately- The NCC recommends that DOE propose an international 

pool of funds specifically set up for the implementation of CCS demonstration projects at 

scale. The U.S. should initiate collaboration within the next year on 5-10 GW of international 

demonstration projects (in addition to the 5-10 GW of U.S.-based projects recommended 

earlier) advancing DOE's program objectives and promoting foreign policy interests. 
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G. Appendices 

Appendix 1- Abbreviations 

ARRA- American Recovery and Reinvestment Act 

CCPI -Clean Coal Power Initiative 

CCS- Carbon Capture and Storage 

CCPS Illinois Clean Coal Portfolio Standard 

CCUS- Carbon Capture Use and Storage 

CFD- Contract for Differences 

COz- Carbon Dioxide 

CRS- Congressional Research Service 

CURC- Coal Utilization Research Council 

DOE- U.S. Department of Energy 

EIA- U.S. Energy Information Administration 

EPA- U.S. Environmental Protection Agency 

EOR- Enhanced Oil Recovery 

EPAct 'OS- Energy Policy Act of 2005 (P.L.109-58) 

EPRI- Electric Power Research Institute 

EU- European Union 

FERC- U.S. Federal Energy Regulatory Commission 

FOAK- First-of-a-Kind (technology) 

GDP- Gross Domestic Product 

GHG- Greenhouse Gas 

GW -- Gigawatt 

HELE High Efficiency, Low Emission 

lEA -International Energy Agency 

IGCC -Integrated Gasification Combined Cycle 

lTC- Investment Tax Credit 

kWh- Kilowatt-hour 

LBNL- Lawrence Berkeley National Laboratory 

LCOE- levelized Cost of Electricity 

MlP Master Limited Partnership 

MW - Megawatt 

MWh- Megawatt Hours 

NCC- National Coal Council 

NGCC- Natural Gas Combined Cycle 

NETL- DOE National Energy Technology laboratory 

NOAK- Next-of-a-Kind {technology) 

NSR- New Source Review 

PPA- Power Purchase Agreement 

PTC- Production Tax Credit 

PURPA- The Public Utility Regulatory Policies Act {P.l. 95-617) 

OECD- Organisation for Economic Co-operation and Development 
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QF- Qualifying Facility 

REC- Renewable Energy Credit 

RGGI- Regional Greenhouse Gas Initiative 

RES- Renewable Energy Standards 

W-Watt 
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Appendix 2- Federal CCS/CCUS Incentive Proposals Introduced in 2015 

• FY 2016 Budget Proposal- The President's FY 2016 budget proposal included two tax 

incentives to assist CCS/CCUS: 

o A 30% investment tax credit for new and retrofitted power plants with CCS capturing 

at least 7S% of the facility's C02 emissions, limited to $2 billion total for all projects, 

Retrofit projects must be on facilities 250 MW or greater in capacity, and must 

capture at least 1 million tpy, 70% percent of the credit must go to projects whose 

fuel source is at least 75% coaL No more than 60% of the credit can be applied to 

either new plants or retrofits, 

o A C02 sequestration tax credit of $50/ton for permanently sequestered C02 that is not 

beneficially used (e.g,, EOR), and a $10/ton credit for COz permanently sequestered 

and beneficially reused, The credit would have a 20-year term, This would be a 

revision and expansion of the existing Section 45Q credit, which provides a $20/ton 

credit for non-E OR sequestration, and a $10/ton credit for EOR sequestration, That 

credit is an annual credit with no duration limit However, the credit is limited to 75 

million tons total for all projects, 

Federal legislation- A number of bills have been introduced in the 114'h Congress to provide 

incentives for CCS, They include the following: 

o S. 2012- On July 30, 2015, the Senate Committee on Energy & Natural Resources 

favorably reported by a vote of 18-4 the Energy Policy Modernization Act of 2015, 

subsequently introduced asS, 2012, Section 3402 of the bill, offered as an 

amendment to the bill by Senator Joe Manchin (D-WV), would repeal the existing coal 

technologies program and carbon capture research and development program and 

establish a new coal technology RD&D program to focus DOE's efforts on 

development of large-scale pilot testing for CCS and other technologies "under real 

operational conditions and commercial scale!' The amendment's funding 

authorization specifically would designate $285 million per year for commercial-scale 

demonstration between FY 2017-2L Section 3401 would list carbon capture, 

utilization, and storage as a specific priority of DOE's Office of Fossil Energy, 

o S. 2089- On September 28, Senate Energy & Natural Resources Committee Ranking 

Democrat Maria Cantwell (D-WA) introduced the American Energy Innovation Act, 

with support from Senate Minority Leader Harry Reid (D~NV), Minority Whip Richard 

Durbin (D-IL), and Democratic Conference Chairman Chuck Schumer (D-NY) among 

others, The bill includes several provisions to support CCS, Section 2141lists carbon 

capture, utilization, and storage as a specific priority of DOE's Office of Fossil Energy, 

Section 5011 provides a production tax credit of l.SC/kWh for clean energy produced, 

to be reduced proportionately depending on by what percentage the facility's COz 

emission rate is below 820 lbsJMWh. Section 5012 provides a 30% investment tax 

credit for CCS equipment, and up to a 30% tax credit for clean technologies, 

depending on by what percentage their COz emission rate is below 820 lbsJMWh, 
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o S. 601- On February 26, 2015, Senator Heidi Heitkamp (D-ND) introduced S. 601, the 

Advanced Clean Coal Technology In Our Nation Act of 2015. The Heitkamp bill 

provides a number of incentives for CCS and CCUS, including among other things the 

following: 

Amends the EPAct '05 to broaden the purposes of DOE's existing coal 

technologies program, and establish a new Transformational Coal Technology 

research, development and demonstration program to study technologies 

such as chemical looping, supercritical C02 generation cycles, pressurized 

oxycombustion, and carbon utilization. 

Establishes a new Section 48E tax credit of 30% for equipment capable of 

capturing, transporting and storing COz. 

Establishes a Clean Energy Coal Bond program to provide tax credits for bonds 

issued for clean coal projects to reduce the cost of borrowing. 

Provides accelerated (seven years} tax depreciation for certain equipment 

installed at coal facilities to reduce C02 emissions. 

Establishes a "variable price support" program for C02 sequestration under 

which applicants would bid to DOE for financial support payments for C02, tied 

to the market price for oil (the contract price for anthropogenic co, is often 

dependent upon the price of oil, which is not stable enough to provide 

sufficient future revenue stream certainty for project financing). 

Provides $2 billion for loan guarantees specifically for CCS projects under 

DOE's loan guarantee program. This is 25% of the program's total funding for 

all energy loan guarantees. 

Establishes a CCS risk management program under which the Secretary of 

Energy would competitively select up to 10 projects to receive financial and 

technical assistance, including indemnification for liability arising from the site. 

o H.R. 1806- On May 20, 2015, the House of Representatives passed H.R. 1806, 

reauthorization of the America COMPETES Act. Among other things, this bill would 

amend the coal and related technologies program authorization in Section 962 of the 

EPAct '05 by authorizing research into chemical looping, supercritical C02 generation 

cycles, pressurized oxycombustion, and carbon utilization. The COMPETES Act also 

would require a study on creation of an expanded C02 pipeline network. 

o H.R. 2883- On June 24, 2015, Rep. Ted Poe (R·TX) introduced the "Master Limited 

Partnerships Parity Act," legislation that would authorize use of the tax-preferred MLP 

structure for numerous types of clean energy projects, including gasification projects 

that capture and sequester at least 75% of C02 produced, and other CCS projects that 

capture and sequester at least 30% of C02 produced. 
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o H.R. 3392- On July 29, 2015, Rep. Scott Peters (D-CA) introduced "The Carbon 

Capture Research and Development Act," that would amend Section 961(a) of the 

EPAct '05 to require the Secretary of Energy to consider the objective of 'improving 

the conversion, use and storage of C02 produced from fossil fuels' in carrying out R&D 

programs. 

o S. 1282- On May 11, 2015, Sen. Joe Manchin (D-WV) introduced legislation to make 

"improving the conversion, use, and storage of carbon dioxide produced from fossil 

fuels" a specific objective of DOE's fossil energy RD&D program. 

o 5. 1283- On May 11, 2015, Sen. Joe Manchin {D-WV) introduced a bill to repeal the 

existing coal technologies program and carbon capture research and development 

program under the EPAct 'OS and establish a new coal technology RD&D program to 

focus DOE's efforts on development of large-scale pilot testing for CCS and other 

technologies "under real operational conditions and commercial scale." It would 

allocate $610 million for each of fiscal years 2017 through 2020, plus $560 million for 

FY 2021, setting aside $285 million per year for demonstration projects. It also would 

repeal cost sharing for projects funded by the program. 

o S. 1285- On May 19, 2015, Sen. Heidi Heitkamp (D-ND) introduced the "Coal with 

Carbon Capture and Sequestration Act of 2015" that would authorize the Secretary of 

Energy to enter contracts for up to 25 years to provide 'price stabilization' support for 

electricity or for C02 captured at an electric generating facility to advance the 

recovery of crude oil or other purposes. 

o S. 1293- On Jun 9, 2015, Sen. Heidi Heitkamp (D-ND) offered legislation that would 

establish the Department of Energy as the lead agency for coordinating permitting at 

"eligible projects," including CCS and CCUS projects and other clean coal projects. The 

bill would require that Federal permit decisions and environmental reviews be 

completed within one year after a complete application is submitted. 

o s, 1656- On June 24, 2015, Sen. Chris Coons {D-DE) introduced the "Master Limited 

Partnerships Parity Act," which would authorize use of the tax-preferred master 

limited partnership structure for numerous types of clean energy projects, including 

gasification projects that capture and sequester at least 75% of C02 produced, and 

other CCS projects that capture and sequester at least 30% of C02 produced. 
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Appendix 3- Case Study: AEP John W. Turk USC Power Plant 

Pulverized coal technologies 

issue 

Coal has long been one of the 

lowest-cost fuels to produce 

electricity in the United States. Not 

only has coal provided consumers 

with reliable, affordable power, it 

has also spurred economic growth 

in areas where it is plentiful. Most 

coal-fired plants are located in coalproducing regions and are 

important sources of jobs and 

economic stability. 

The increasing scope and 

stringency of environmental 

regulations continues to pose 

I technical and financial challenges 

to the electric utility industry. 

These challenges are driving 

decisions to upgrade or retire 

existing coal-fired generating units, 

and are strongly influencing the 

planning of new generation 

projects. 

In a pulverized coal (PC) plant, the 

coal is ground into fine part ides 

and blown into a furnace where 

combustion takes place. The heat 

from the combustion of coal is 

used to generate steam to supply 

a steam turbine that drives a 

generator to make electricity. 

Subcritical steam generation units 

operate at pressures such that 

water boils first and then is 

converted to superheated steam. 

Subcritical operating conditions 

temperature steam through the turbine, a supercritica! 

is more efficient than a subcritical unit. 

Ultra-supercritical (USC) steam generation currently is the most efficient 

technology for producing electricity fueled by pulverized coal. 

operates at supercritical pressure and at advanced steam 

1,1002F (5932C). These temperatures and pressures enable 

operation of the turbine cycle, This increase in 

consumption, and thereby reduces emissions, solid waste, 

operating costs. 

are !l''."."."'J.ii"'.C£€fl!e_cl_!9_~..".-._--'-----------------------------·--------' 
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superheated steam, with a 

single reheat to l,Ooo•F. 

National Coal Council- Leveling the Playing Field 

At supercritlca! pressures, water is 

heated to produce superheated 

steam without boiling. Supercritical 

steam cycles typically operate at 

3,600 psig, with l,OOO•F -l.OSO•F 

main steam and reheat steam 

conditions. Ultra- supercritica! is a 

term applied to supercritical 

pressures and temperatures above 

1100 2F. 
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National Coal Council Leveling the Playing Field 

the 600-megawatt (MW) John W. Turk, Jr., Power Plant in southwestern 

commitment to the responsible use of coal as a fuel source. The Turk Plant is 

plant AEP has built in more than two decades and represents the future of coal-based 

continue to advance. The Turk Plant is the only operating U.S. power plant to use 

ullra-·suoe•-cr•,nca• technology and is among the nation's cleanest, most efficient pulverized coal plants. 

rornn>er.cial operation in December 2012 after a variety of regulatory and legal challenges 

officially dedicated in April 2013. AEP SWEPCO and the Turk Plant received 

in 2013: 

Electric Institute's (EEl) Edison Award, the electric power industry's most prestigious 

for the completion and commercial operation of the plant 

Fn•7in,ppr·inn Magazine's "Best Coal-fired Project" for its cleaner, more efficient 

generation and new technology, and the magazine's "Plant of the 

Enain1eerina News Recard Texas & Louisiana Magazine's "Best Project Winner" in the 

category and "Best Safety Award" winner by for its outstanding 

rnn''" ~<cti•m quality and craftsmanship, and the high-priority safety culture of site 
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Appendix 4- Commercial Project Financing and the Role of Incentives 
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Appendix 5 - Case Study: Contracts for Differences 

The UK has developed mechanisms to help low-carbon energy projects be more competitive in an 

open market. With huge storage potential in the North Sea and clusters of industrial C02 sources, 

the UK is well-positioned to be a leader of CCS in the European Union. While the country has set 

aside funding for CCS projects, the CFD mechanism could be an important source of support for large 

CCS projects as they come online. 

CFO support low-carbon sources of energy by making investment more palatable due to reduced 

uncertainty about electricity pricing, while also protecting consumers from overpayment. 

Essentially, CFDs provide long-term price stabilization, allowing lower cost capital investment and, 

thus, a lower net cost to consumers. The CFD is just beginning to be used and the first set of 

allocations is limited to projects using onshore wind, solar PV, energy from waste with combined 

heat and power, and landfill gas and sewage. 

CFDs require generators to sell electricity to the market as usual. However, to reduce exposure to 

fluctuating energy prices CFDs include a pre-determined strike price. This strike price operates 

against a reference wholesale market price. If the reference wholesale market price is lower than 

the strike price, the generator will be paid the difference between the two prices. Similarly, if the 

reference price is higher than the strike price the generator will have to pay back the difference. 

Although CCS projects are not currently listed in the CFD allocations, future CFD allocation rounds 

are expected to include CCS, and two major projects are moving forward in the UK. The Peterhead 

Project in Aberdeenshire will capture about one million tonnes per year (Mtpa) from an existing 

natural gas combined-cycle plant and store it under the floor of the North Sea. The White Rose 

project will capture about 2 Mtpa from a new 448-MW (gross) oxy-combustion coal-fired power 

plant. 
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Appendix 6- Case Study: FutureGen 

The FutureGen 2.0 project was to demonstrate the retrofitting of an existing coal-fueled power plant 

with oxy-combustion technology and fully integrated C02 capture. All captured COz was to be 

transported via pipeline to a deep saline geologic formation for permanent storage. Ultimately, the 

project did not proceed to full construction due to the DOE's decision to suspend Federal costsharing after concluding that there would be insufficient time to expend the project's Federal funds 

prior to expiration. As the project had secured all its major permits, had negotiated most 

commercial contracts, and was in the final phase of commercial financing, substantial policy-related 

lessons-learned can be drawn from it. 

It is important to highlight that being a FOAK project, both with respect to the oxy-combustion 

technology and the fully integrated geologic storage, the State of Illinois and the Federal government 

took certain policy-related measures to help reduce the FOAK cost and risk down to a level that a 

commercial financing could bear. Inevitably, FOAK technologies require more aggressive policyrelated incentives than mature CCS technologies will require. Further, in the power sector, policyrelated incentives must be robustly designed to be effective in different corporate environments. 

That is, policy-related incentives must meet the needs of regulated utilities, merchant plants, 

contracted plants, and non-profit rural electric generation companies, if CCS is to effectively 

penetrate the coal-based generation market. Further, a robust policy framework for CCS 

deployment must include complementary changes to both Federal and State policies. 

Policy-related lessons-learned are discussed below in the context of selected project 

accomplishments and challenges. 

Capital cost Buy-Downs- As a FOAK project, the capital cost buy-down provided by DOE's 

commitment of $1 billion dollars to the project was a necessary first step to establishing financial 

credibility In the marketplace. While Federal budgets are likely to be tight in coming years, the 

Department should consider whether larger investments in a limited number of projects versus 

spreading DOE funding broadly in smaller amounts would increase the likelihood of FOAK project 

success. CCS projects are by their very nature large capital allocations as distinct from smaller MW 

low carbon technologies (e.g., wind and solar). However this is the balance between stable baseload 

power and intermittent power. Further, there is no policy parity between renewable projects and 

coal projects when it comes to DOE grant taxation. Many energy projects are structured as 

partnerships (e.g., LLCs or MLPs). While DOE renewable grants are non-taxable when received by a 

partnership, fossil grants are taxed as income nominally resulting in a loss of approximately one-third 

of the grant funds. To avoid this untenable taxation, fossil projects must be structured as a Ccorporation, which subsequently complicates commercial financing and increases project risk. DOE 

should advocate for policy parity on grant taxation. 
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Capital Financing Guarantees- DOE currently lacks the statutory authority to combine loan 

guarantees and grant funding on individual project. This is not the best use of two complementary 

policy tools. The Department should advocated for increased statutory authority that would allow 

the use of both guarantees and grants on the same project with an aggregate cap on DOE's cost 

exposure (e.g., 80% of total capital) 

Operating Cost Coverage- Operating a coal-fueled power plant with CCS, particularly when 

employing geologic storage, requires a mechanism to cover the increased cost of generating lowcarbon power. FutureGen 2.0 was the first project to secure an investment-grade PPA under the 

Illinois Clean Coal Portfolio Standard (CCPS), which provided a level playing field for low carbon 

technologies (i.e., renewables and CCS). The structure of the PPA allowed FutureGen 2.0 to engage 

financial markets as a long-term contracted asset. In FutureGen 2.0's case, the PPA covered the 

incremental cost of deep saline storage for which there is no traditional economic driver. The CCPS 

could serve as a model for other States. At a Federal level a substantial refundable tax credit would 

help offset the cost of operation for a deep saline storage site. 

Power Plant Air Permitting- FutureGen 2.0 benefited from Illinois EPA's modification of the power 

plant's existing permit. The nature of the permit provided substantial flexibility that would have 

proved valuable in the early years of operating a FOAK plant. DOE, working with EPA, should 

consider what air permitting flexibility could be provided to other FOAK projects. 

COa Pipeline Permitting- The State of Illinois passed new legislation regarding the siting of C02 

pipelines that enabled FutureGen 2.0 to receive a final pipeline permit as well as the right of eminent 

domain for pipeline siting. Through substantial stakeholder involvement activity, the FutureGen 2.0 

project remained hopeful that the exercise of eminent domain would not be necessary; however, on 

most projects this policy mechanism will be required. 

C02 Storage Rights- A remarkable project achievement was the project's ability to work with local 

landowners to acquire control, on a free-market basis, 100% of the necessary pore space. This 

success is due in part to the public community placing a high value on the job creation and the 

project's associated training center. On most CCS projects, it will likely be necessary to have some 

form of unitization or eminent domain when private property is involved. This is predominantly a 

State policy issue. On Federal lands, a granting of pore space rights would be necessary. 

C02 Storage liability- The State of Illinois passed unique legislation that required certain operator 

responsibility, as well as having the State taking on certain long-term stewardship and liability 

responsibilities. Unquestionably, this help improve the commercial financeability of the project. 

This landmark legislation could serve as a model for Federal or State policy. 
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Appendix 7 - Case Study: Government Support and a Strong Business Case Energize Boundary Dam 

The Boundary Dam Power Plant in Saskatchewan, Canada has become a flagship clean energy 

project and has set the bar for CCS/CCUS projects around the world. The world's first-ever, largescale, coal-fired post-combustion C02 capture project began operation on October 2, 2014. 

However, as with most first-of-its-kind energy projects CCS at Boundary Dam would never have 

come to fruition without the support of the Saskatchewan and Canadian governments. According to 

a report issued by the lEA, "Federal funding was the catalyst for converting SaskPower's clean coal 

power concept into a fully engineered design." 

Active support from the Saskatchewan government began in 2007 to secure the Federal funding 

needed to support SaskPower's landmark clean coal project. The Saskatchewan government was, in 

part, motived by the business case made by SaskPower beyond the demonstration of coal-fired CCS. 

Royalties from C02-EOR, extending the life of an important oil field in the region, maintaining jobs in 

oil production, and supporting a technology to allow for Saskatchewan to continue using its vast 

lignite reserves in a carbon-constrained future helped support the business case. 

SaskPower created the business case-and the Saskatchewan government took that case to the 

highest levels of government, successfully securing $240 million in Federal funding in 2008. These 

funds were instrumental in completing the plant design-a critical step where similar projects 

have stumbled. 

This support was especially visionary because when it was provided there were no regulations in 

place, at either the Federal or provincial level, that required co, to be captured and stored. Thus, 

there were also no offsets available to help support the project. Regulations were not enacted for 

four years after government support was committed. 

CCS at Boundary Dam can be considered a joint venture between the Canadian and Saskatchewan 

governments and SaskPower. In addition to the financial support, the governments have been vocal 

on the merits of the project, both nationally and internationally. The Boundary Dam project, 

including the role of government in advancing the project, is a prominent example of the public· 

sector collaboration necessary to advance clean coal projects around the world. 
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Government and Business Partnership (left to right): SaskPower Board Chair Rob Pletch; the 

Honourable Bill Boyd, Minister Responsible for SaskPower; Saskatchewan Premier Brad Wall; the 

Honourable Greg Rickford, Canada's Minister of Natural Resources; and SaskPower President and 

CEO Robert Watson cut the ribbon at the official launch of the Boundary Dam carbon capture and 

storage facility. (Image credit: SaskPower) 

A World's First: Boundary Dam CCS Project (Image credit: SaskPower) 
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National Coal Council-leveling the Playing Field 

1 Mike McKinnon, Newly Revealed SaskPower Chart Shows Capture Performance Not Improving, GLOBAL NEWS, Nov. 2, 

2015 available 

. ''·"~"-'3'.'''',. g•·••ll)l.oir;J[fi•;<c.•QrBl~G•e~cll\i~bo.nt>Yl\QC•Y·:.t1li!.iL?J"<t">Jss.:QD.:llL~llciJ•Jl'::th.e:.c I.DJ.•ilt••.:<Jea.cJip•:k,l ("The vast majority 

of new power stations in China and India will be coal-fired; not 1may be coal-fired1

; will be, So developing carbon capture 

and storage technology is not optional1 lt is literally of the essence."} 4 Lori Rugh, American Wind industry: Past and Future Growth 4, AM. WIND ENERGY ASS'N available at: 

DEP'T OF ENERGY {Aug. 2015) 

available at: n.tt.R.:lli2•'eD~'LJ'LQ);L8l;ill.lEQJ!,Lt!!<~sL6ll)l2L.mu·J.£;u..Cu.1.'l.\.'Yclli1Jilc:IJL1.0l''llc':O!Yia.u<etlle;)o.t:tl1!glJicgll!sl!:.Vl..P•:lJ 

{showing, as well, that wind prices reached a high of nearly $70/MWh in 2009, driven by increases in the cost of wind 

turbines). 

7 AM. WIND ENERGYAss'N, AWEA white paper,' Renewable Production Tax Credit has driven progress and cost reductions, 

but the success story is not yet complete {Sep, 10, 2015) 

{"The Production Tax Credit {PTC) and 

alternative Investment Tax Credit {lTC) have enabled private sector investments in the American workforce, domestic 

manufacturing, and R&D that have significantly reduced the cost of wind energy.") 8 SOLAR ENERGY INDUS. ASS'N, Solar Market Insight Report 2013 Year in Review,"·''~"·'"''·" ''·'•'''·"''oL '·"-'''' 

9 1d. 

10 SOLAR ENERGY INDUS. Ass'N, Solar Industry Data: Solar Industry Breaks 20 GW Barrier- Grows 34% Over 2013, 

13 Budgets for "Renewables" reflect funds budgeted to the Office of Energy Efficiency and Renewable Energy for the 

following line items: "Solar Energy," "Wind Energy," "Water Energy," and "Geothermal Technologies." Budgets for "CCS" 

reflect funds budgeted to the Office of Fossil Energy for the line items: "Carbon Capture" and "Carbon Storage." As 

noted ln the chart, no funds were budgeted for CCS demonstration projects (i.e, CCPI}. The budget for CCS does not 

reflect funding for technologies not under the CCS budget that have application beyond such as 

oxycombustion and chemical looping. Budgets available at tlttrJ;/.IYL'!<'!!.cCD·.~rti~.[[O_\'[Qh!flg~_t:p_t~tQr:tm•L'C~. 

Molly Sherlock and Jeffrey Stupak, ENERGY TAX INCENTIVES: MEASURING VALUE ACROSS DIFFERENT TYPES OF ENERGY RESOURCES 7, 

Tbl. 2, CONG. RESEARCH SERV., R41953 {Mar. 19, 2015) available at: D1JQ:lillYi'!!:<L.f0.SJli!115flf21.c:siJ.:ml~lJI 

15 While approximately $30 mill ian of this credit has been claimed, we could find no evidence of the credits being 

claimed by power projects with CCS, 16 NAT'L COAL COUNCIL, fOSSIL FORWARD- REVCTAUZING CCS: BRINGING SCALE & SPEED TO CCS DEPLOYMENT 12 (Feb. 2015) available 

at: _[ltt[J :J.b'L'!i\Y"2i'1iQ!.!.il.ifQ2JJ:•lo.rl'l.ilc?IfJ.'ll!l':li~"/2Q1 ?il:C.~ll.:fcmY·3I.cLl1.evlLlli.sill!tO::J;.Cd'l~.C::!'ill.QrQ;C<::£:,51;t.<c;il'.PJll.: 

17 Department of Energy Oversight: Status of Clean Coal Programs: Hearing Before the Subcamm. on Oversight and 

Investigations of the H. Comm. on Energy and Commerce (Feb. 11, 2014) available at: 

ic.tipJbJccc?, L12!'Sfclilrilm<tl£\i.cg?·LI.ELif'P1Ll!llcl\i;z!JI.JlllZc'LU.tlti~cG.cLL:bl£Ql: Y'Lilil!rc.imE:'li19.L1.'l.:ZJJ.cr~tJJ {testimony of 

Dr.lulio Friedmann, Deputy Assistant Sec'y for Clean Coal {now Assistant Sec'y for Fossil Energy), U.S. Dep't of Energy) 

("Commercia!"scale demonstrations help the industry understand and overcome start~up issues, address component 

integration issues, and gain the early 1earning commercia! experience necessary to reduce technology risk and secure 

private financing and investment for future plants."). 

18 NAT'L COAL COUNCIL, FOSSIL FORWARD, supra note 16, at 12{citing INT'L ENERGY ASSOC., Technology Roadmap: Carbon 

Capture and Storage 6 {2009) available at: 
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National Coal Council leveling the Playing field 

halve C02 emissions levels by 2050 increase by 70%.") and INTERGOVERNMENTAL PANEL ON CLIMATE CHANG€ WORKING GROUP Ill, 

CUMATE CHANGE 2014: MITIGATION OF CLIMATE CHANGE 60, Fig. TS-13 (2014) available at: 

IJtJQ:/[[§.Q9rtiOJ.ti&il)"iQI:l]0l4",orgJrs1'9£!LJ.Ll£:<; __ ~ill.l"""lll"~--tc!JIA:>£it(showing a median cost increase without CCS of 138%)}; 

see also INT'L ENERGY ASSOC., ENERGY TECHNOLOGY PERSPECTIVES 2012: PATHWAYS TO A CLEAN ENERGY SYSTEM 11 (2012) available 

at: ("CCS is the only technology on the 

horizon today that would allow industrial sectors (such as iron and steel, cement and natura! gas processing) to meet 

deep emissions reduction goals , ... The additional investment needs in electricity that are required to meet {C02 

reduction goals] [would add] a total extra cost of USD 2 trillion over 40 years."). 

191NT'L ENERGY ASsOC., TECHNOLOGY ROADMAP CARBON CAPTURE AND STORAGE 8 (2013) available at: 

14 1NT'L ENERGY AGENCY, SOUTHEAsT AsiA ENERGY OUTLOOK 2015 9 (Sep. 2013) available at: 

Herzog, Pumping co, underground can help fight climate change. Why is it stuck in second gear?, 

THE(ONVERSATlON.COM, Mar. 12, 2015, 

COAL UTILIZATION RESEARCH COUNCIL and ELEC POWER RESEARCH INST", THE CURC-EPRI ADVANCED COAL TECHNOLOGY ROADMAP 2 

(July 2015) availoble at: U.S. ENERGY 

INFO. ADMIN., Electric Power Monthly- February 2015, Feb. 2015.). 

NATIONAL COAL COUNCIL, RELIABLE & RESILIENT: THE VALUE OF OUR EXISTING COAL FLEET 23 (May 2014) available at: 

29 U.S. ENERGY INFO, ADMIN., ANNUAL ENERGY OUTLOOK 2013 42 (Apr" 2013) DOE/EIA-0383(2013) available at: 

30 Memorandum from Coal and Uranium Analysis Team to John Conti, Assistant Adm'r for Energy Analysis and Jim 

Diefender, Dir., Office of Electricity, Coal, Nuclear, and Renewables Analysis, U.S. Energy Info. Admin., Notes from the 

Future Operating and Maintenance Considerations for the Existing Fleet of Coal-fired Power Plants workshop held on 

June 16, 2015 2, June 18, 2015 available at: 

'n See infra Appendix 3 for more information on the first ultra-supercrit!cal power plant in the United States, AEP's John 

W. Turk Jr., Power Plant. 

33 WORLD COAL ASSOC., A GLOBAL PLATFORM FOR ACCELERATING COAL EFFICIENCY (2014) available at: 

34 1NT'L ENERGY ASSOC., TECHNOLOGY ROADMAP, supra note 19, at 24, Fig. 6. 

33 See, e.g., Tom Randall, Fossil Fuels Just Lost the Race Against Renewables, BLOOMBERGBus., Apr. 14, 2015, 

Lcf1t!fl<csD1QJ;i"~C>1:J'I/JC"Iss,ii-Iugl:''l\<s!JO.s!:lJJ·~cfiJ.ce .. :,egil]r1i(:re_n,,'o'i,,lJI§ ("The price of 

wind and solar power continues to plummet, and is now on par or cheaper than grid electricity in many areas of the 

world."). 

36 Renewables proponents have argued for continuing subsidies based on the alleged latent subsidy of infrastructure 

geared toward fossil fuel use. See Kate Gordon, Why Renewable Energy Still Needs Subsidies, WALL SL JouRNAL, Sep. 14, 

2015, if they're now, 
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National Coal Council- Leveling the Playing field 

finally, cost-competitive at the point of sale, !ow-carbon technologies are still working with an infrastructure ... buHt for 

a world powered by fossil fuels.") 

37 NATIONAL COAL COUNCIL, REUABLE & RESJUENT, supra, note 27, at 12. 

38 CURC-EPRI ADVANCED COAL TECHNOLOGY ROADMAP, supra note 26, at 8. 

39 U.S. ENERGY INFO. ADMIN., Direct Federal Financial Interventions and Subsidies in Energy in Fiscal Year 2013, Mar. 12, 

2015, llllilJll•Y':!i"VcfJc'!oR,"i/Jl!lillleiliLL§Q\Le.?'~"L~llQdlllil. 

40 Molly Sherlock and Jeffrey Stupak, ENERGY TAX INCENTIVES, supra note 14. 

41 The effects have led to retirements of both coal and, most recently, nuclear. See, e.g., Rebecca Smith, Entergy Plans to 

Shut Down Pilgrim Nuclear Plant by June 2019, WALL ST. JOURNAL, Oct. 13, 2015, ll11.tJ.:LL\.vYY'!.IcCfi&C:QflJ!JiL\Klcs/!£!liU:al': 

("Entergy Corp. said Tuesday it will close its aging 

Pilgrim nuclear power plant in Massachusetts by mid-2019, citing low power prices, regulatory challenges and public 

policies that it says disadvantage nuclear plants. . For example, the U.S. intends to limit carbon-dioxide emissions from 

power plants by 2030, but Mr. Mohl said some State and Federal policies that favor clean energy specifically exclude 

existing nuclear plants, even though they emit no carbon."). 

Phillip Brown, U.S. RENEWABLE ElECTRICITY: HOW DOES WIND GENERATION IMPACT COMPETITIVE POWER MARKETS? 15, CONG. 

RESEARCH SERV., R42818 (Nov. 7, 2012) available at: [1t1JJ2;L/:y•tJ:IJiVJ:~:U:iii:!JiPliLSiJ:l1~ici':fl.4] J1 

"ld. 

44 A Section 45 credit also applies to refined coal and Indian coal. This credit operates differently, and is based on tons of 

qualified coal produced, rather than electricity produced. 

" Oversight of the Wind Energy Production Tax Credit: Hearing Before the Subcomm. on Energy Policy, Healthcare, and 

Entitlements of the H. Common Oversight and Gov't Reform (Oct. 2, 2013) available at: 

(testimony of Rob Gramlich, 

Senior Vice President, Am. Wind Energy Ass'n.) {"A single incentive, the Production Tax Credit1 is by far the dominant 

policy driver for wind energy in the US."). 

26 U.S. C. § 48(a)(3)(A){i) (applying credit to "equipment which uses solar energy to generate electricity, to heat or cool 

{or provide hot water for use in) a structure, or to provide solar process heat, excepting property used to generate 

energy for the purposes of heating a swimming pooL"}. 

47 U.S. DEP'T OF ENERGY, Portfolio Nov. 10, 2015). These 

figures do not include loan guarantees for energy storage projects, which disproportionately aid intermittent renewable 

energy sources by storing energy produced but not needed (typically during off-peak hours). 

"California price listed at $12.88/ton as of October 16, 2015 ($11.68/ton). CLIMATE POLICY INITIATIVE, California Carbon 

Dashboard, The most recent RGGI auction price is $6.02/ton. Gerald Silverman, RGGI 

Carbon Prices Continue Upward Trend, BNA.COM, Sep. 21, 2015, !1.ti.PI//Qil3,,rrQiJ'll!cr'''·''·'"·'-"''- Ri'L''LY2_C24'-'"JY6ci''Jf. 49 Glen Barbose, Renewable Portfolio Standards in the United States: A Status Update 20, lAWRENCE BERKELEY NAT'llAB., 

Nov. 6, 2013 available at: (presentation to the StateFederal RPS Collaborative National Summit on RPS, Washington, D.c.), 

'

0 ld. at9. 

51 Jd. atS. 

52 CAL PUB. UTIL COMM'N, CALIFORNIA NET ENERGY METERING RATEPAYER IMPACTS EVALUATION 6 (Oct. 28, 2013) available at: 

See, e.g., American Energy Innovation Act, S. 2089, 114th Cong. (2015)( introduced by Sen. Maria Cantwell (D-WA), 

Ranking Democrat on the Senate Energy and Natural Resources Committee and cosponsored by Minority Leader Harry 

Reid (D-NV), Assistant Minority Leader Dick Durbin (O-Il), and Senate Democratic Conference Vice Chair Chuck Schumer 

(D-NY)). 

55 U.S. ENERGY INFO. ADMIN, lEVEUZED COST AND LEVEUZED AVOIDED COST OF NEW GENERATION RESOURCES IN THE ANNUAL ENERGY 

OUTLOOK 2015 3 (June 2015) available at: DllJUL"i~'"Cl0..RQYJJflll':f.iilli'fa<c9J.P~:r£.g>pfJf_l,l0/ _ _&r']1f:i>il_~_~flJlQI· 

56 GLOBAL CCS INST., THE COSTS OF CCS AND OTHER TECHNOLOGIES- 2015 UPDATE 9, Fig. 5.2 (July 2015) available at: 

57 U.S. ENERGY INFO. ADM1N, LEVEUZED COST, supra note 55, at 7. 

Mike McKinnon, Newly Revealed SaskPower Chart, supra note 1. 
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National Coal Council- Leveling the Playing Field 

ss NAT'L COAL COUNCIL, FOSSIL FORWARD, supra note 16, at Ch, E. 

60 L STEPHEN MELZER, Carbon Woxide Enhanced Oil Recovery {C02 EOR}; Factors Involved in Adding Carbon Capture, 

Utilization and Storage (CCUS} to Enhanced Oil Recovery 8, Feb. 2012 available at: 

See, e.g., John Harju and Ed Steadman, The Energy & Environmental Research Center's Economic Case for CCUS: 

Reducing Capture Costs and Increasing Demand for Commodity co,, ENERGY & ENV'T RESEARCH CTR., Mar. 25-27, 2014 

available at: b1\n:ILV£N.'~,f.s!fol:unl.o::sl:9.!!lill.~0!l<:>f11Lds:c:;mfnt:;L;_c:o.l)i2.9'.1.4,1_St:;aclm.:m:Ws•r:l<~:bgtl:?·.e()'UIQ~l'LR•)f 

for the Carbon Sequestration leadership Forum Technical Meeting); Vella Kuuskra, Increasing the Size of the CCUS Prize: 

The Potential and Economic Viability of Storing C02 and Producing Oil from the ROZ of the Permian Basin Greatly 

Enhances the CCUS Option, ADVANCED RES.INT'L, INC., Oct. 5, 2015 available at: 

2nd Biennial co, for EOR as CCUS Conference). 62 CURC-EPRI ADVANCED COAL TECHNOLOGY ROADMAP, supra note 26. 

"ld. at 29. 

prepared for the 

64 While Congress authorized the CCPI program with EPAct '05, Congress created the program in 2001 appropriations 

language. Fiscal Year 2002 Department of Interior and Related Agencies Appropriations Act, P.L. 107-63, 415 Stat. 414, 

453 (2001). DOE began project solicitations for CCPI Round 1 in 2002. U.S. DEP'T OF ENERGY OFFICE OF FOSSIL ENERGY, MAJOR 

DEMONSTRATION PROGRAMS: PROGRAM UPDATE 2013 2-1 (Sep. 2013) DOE/FE-0565 available at: 

Kemper Energy Facility. MAJOR DEMONSTRATION PROGRAMS, supra note 641 at 3-17. However, that grant was not for 

Kemper's CCS technology. 

" ld. at 2-5, Ex. 2-5. 67 Peter Folger and Molly Sherlock, CLEAN COAL LOAN GUARANTEES AND TAX INCENTIVES: ISSUES IN BRIEF 6, CONG. RESEARCH SERV. 

(Aug.19, 2014) R43690 available at: ntt~"IJ:!,:Y!L~£J.Q",R'J!.Ii'llliiCf.1J.fl_1,~c,r!-t<+~.l>!!\L!19l· 

68 Congress allocated $1.25 billion for a Phase II of 48A investment tax credits. I d. at 7. Of that amount, the IRS allocated 

$1,009,436,000 to three projects in the 2009-10 first allocation, no amounts in the 2010-2011 second allocation, and 

$103,564,000 to one project in the third allocation; leaving unallocated $137,000,000 for qualifying advanced projects 

utilizing lignite. U.S.INTERNAL REVENUE SERV., Notice 2010-56, 2010-39 I.R.S. 398 (Sep. 27, 2010), available at: 

"'-"'-"-'""~''""L"""'L!:L:J~L!'''-'L".c"'L~'.!.: Notice 2011-62, 2011-40 I.R.S. 483 (Oct. 3, 2011), available ot: 

I2J:liJ~/J.li'!'!E>'LU!:io.ES!JLIJ!l'QL'l!Lt1rs:'!lLl:1HilJ;:Qt Notice 2013-2, 2013-2 I.R.B. 271 (Jan. 7, 2013) available at: 

The IRS recently announced that $1,104,000,000 of 48A credits were made 

available for reallocation due to forfeitures of previously allocated Phase I credits and unallocated Phase II credits. U.S. 

INTERNAL REVENUE SERV., Announcement 2015-14, 2015-10-I.R.B. 722 (Mar. 9, 2015) available at: 

https:j /www. i rs.gov /pub/irs-i rbs/i rb 15-10.pdf. 59 Figure as of June 1, 2014. INTERNAL REVENUE SERV., Notice 2014-40, 2014-271.R.B. 100 (June 30, 2014) available at: 

e.g. S. 2089, supra note 54. Other recommendations can be implemented by DOE without statutory changes. 73 Note that the House and Senate legislation that has been introduced to extend MLP status to renewables and CCS. 

Master limited Partnership Parity Act of 2015, H.R. 2883 and S. 1656, 114th Cong. (2015). 74 CURC-EPRI ADVANCED COAL TECHNOLOGY ROADMAP, supra note 26. 
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8115/2017 The Nnxt Shale Revolution? 

Revolution? 

The astonishing promise of enhanced oil recovery 

DEC 29, 20141 By SAMUEL THERNSTROM 

Just five years ago, almost no one outside the natural gas 

industry had heard of fracking, even though the basic 

technologies were not new; today, the shale gas revolution 

has transformed America's energy markets, with profound 

effects for economic growth, competitiveness, security, and 

environmental quality. In a nation still deeply concerned 

about its energy future, this extraordinary success story 

should prompt the question: Can we do it again? 

The answer is yes-if we correctly understand both the model for innovation that 

shale gas exemplifies and an opportunity that now exists to emulate the shale model. 

That opportunity involves exploiting a technique called "enhanced oil recovery" 

(EOR). 

Like fracking on the eve of its success, this concept is virtually unknown to most 

Americans, yet it rests not on pie-in-the-sky technological dreams but on the 

application and retlnement of proven technologies that companies have been 

developing for decades. Like fracking, enhanced oil recovery has the potential to 

recover staggering quantities of hydrocarbons that were previously known but 

considered inaccessible. As with fracking, the primary players will be the private 

sector-but public policy has a crucial role to play in establishing the necessary 

conditions and providing the impetus for this market to take off. Most tantalizingly, 

enhanced oil recovery should be less controversial than fracking, because it also 

offers the opportunity to radicaliy reduce greenhouse gas emissions from electric 

power generation (and other industries). 

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The shale gas revolution may have seemed to emerge out of nowhere, but it in fact 

represented the maturation of an industry that had been developing for decades, 

driven by advances in multiple technologies-hydraulic fracturing, directional 

drilling, and the combined-cycle natural gas power plant. In the nuance-allergic world 

of politics, this story is often spun either as a triumph of the free market or as proof of 

the power of government-funded R&D. In fact, both the government and the private 

sector deserve credit, and success depended in no small part on getting the 

relationship between the two sectors right. 

Reviewing this history in a recent National Affairs essay, Jim Manzi identified three 

factors that drove the shale gas revolution: (1) America's system of property rights and 

pricing, which allowed innovators to reap the rewards of their work; (2) our highly 

skilled and competitive workforce and market for oil exploration, extraction, and 

associated services; and (3) government support for research, development, 

demonstration, and commercialization of these technologies. 

As Manzi observes, we cannot know how much weight to give to the third factorthere's no way of knowing what would have happened without it-but the very 

companies that led the fracking revolution have been the first to acknowledge the 

significance of government support. It takes nothing away from the entrepreneurial 

geniuses who saw and pursued the potential of shale gas to acknowledge the public 

policy contributions to their success. 

Federal support for shale gas development wasn't limited to basic research and 

development. It ran the gamut: early R&D support through the Eastern Shales Gas 

Project in 1976, a hand-off of technology to the private sector via the Gas Research 

Institute (a public-private institution funded by a charge on interstate gas sales), 

support for refinement of the technologies through further federal R&D in the 1980s, 

and a boost to its commercialization through tax incentives for the use of 

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"unconventional gas" (as it was then called). Long after the core technologies were 

first developed, federal support for their refinement and commercialization 

continued. 

Manzi's essay looks at the most important part of the equation-the revolutionary 

advances in technology for extracting gas from shale-but there was another element 

of the story that wasn't inconsequential: the combined-cycle gas turbines that turn the 

gas into electricity. Why do we have such efficient natural gas power plants? Because 

the Department of Defense invested well over a billion dollars over three decades to 

improve the performance of jet turbines for military aircraft-and then the 

Department of Energy spent millions more to apply that knowledge to power 

generation. 

An unfortunate legacy of the Obama administration's tainted record on green energy 

investments has been a loss of conservative support for this model of innovation. 

Overreach-and-backlash may be an unavoidable dynamic in politics, but it would be a 

mistake to assume that this administration's missteps on energy innovation reflect 

inherent obstacles to success in the field. 

In fact, the opportunity that enhanced oil recovery offers today is much clearer than 

that of shale gas in 1976, when President Ford first focused federal attention on its 

potential. EOR's core technologies work well, and the market is much more advanced 

than shale gas was in the 1970s. But a focused public push to expand the market for 

EOR and bring next-generation technologies forward could still have profound effects 

on America's energy future. 

Using known and next-generation technologies and processes, enhanced oil recovery 

could increase domestic oil production-mostly from existing wells, not new fields 

-by tens of billions of barrels. Public policies to jump-start this nascent market could 

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significantly enhance our energy security, improve our balance of trade, and generate 

tens of billions of dollars in revenue for the federal government and trillions in 

economic activity over the next half-century. 

Equally important is the answer offered by EOR to two of the most pressing questions 

in energy policy: What is the future of coal in this country, and what can the federal 

government do to reduce the risks of climate change?The answer EOR offers is 

uniquely compelling: Coal stays in our energy miY while almost all of its carbon gets 

trapped underground. 

The key to this opportunity lies in the fact that carbon dioxide is the essential 

ingredient in enhanced oil recovery operations. And in contrast to EPA's divisive, 

expensive, and likely ineffective approach to regulating carbon emissions, EOR would 

give American companies an opportunity to make money putting carbon dioxide 

underground while producing oil, making this a wealthier, more productive country 

with a stronger, more secure energy economy and a cleaner environment. 

Drillers have long understood that they leave most of their product in the ground. As 

oil is pumped, the pressure underground drops and it becomes harder to extract what 

remains. Typically, only about one-third of the oil in a given location can be 

economically removed. As a result, many supposedly "depleted" wells actually still 

contain most of their oil-just waiting for a technology that will make it economical to 

extract it. 

In the early 1970s, drillers in west Texas figured out how to do just that, and the 

remarkable secret to their success was carbon dioxide. Pumping carbon dioxide into 

depleted wells not only increases the pressure, it also acts as a solvent, helping to 

separate oil from the cavities in the rock where it is trapped and the water it is often 

mixed with. This process enables oil companies to extract as much as another third of 

a site's oil-essentially doubling a well's productivity. 

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One might think that such a remarkable technology would be an overnight sensation. 

But in fact, we are nowhere near capitalizing upon EOR's full potential. Since the 

1970s, oil companies have injected about a billion tons of carbon dioxide into 

"depleted" wells, producing roughly 2.5 billion barrels of oil. About 6 percent of the oil 

produced in America is now extracted using this technique. We know it works-but 

it's still a niche market. 

What's holding us back? A shortage of carbon dioxide. The carbon dioxide used in 

EOR operations is predominantly geologic-companies tap into underground deposits 

and extract C02 for enhanced oil recovery and other commercial applications. That's 

how it's been done since the 1970s, but two important things have changed in recent 

years. Climate change has become the preeminent environmental concern, and new 

studies have shown that there is much more oil reachable through EOR than had been 

previously understood-so much so that geologic carbon dioxide supplies aren't 

nearly sufficient. If we want to get that oil, we'll have to capture carbon dioxide from 

industrial sources, such as coal-fired power plants. 

Which brings us to the interesting place we find ourselves today: Our nation's top 

environmental goal is reducing carbon dioxide emissions. And one of our top energy 

priorities is maximizing production from domestic oil reserves. Capturing carbon 

dioxide from power plants and using it for EOR could produce billions of barrels of oil 

while simultaneously putting billions of tons of carbon dioxide underground forever. 

Yet policymakers are doing next to nothing to take advantage of this unique 

opportunity. Instead, Washington is preparing to fight a pitched legal and political 

battle over proposed EPA power plant regulations that will, even if implemented, 

make barely a dent in America's carbon emissions. 

Why is so much carbon dioxide being released into the atmosphere if it's valuable? 

Because the costs and benefits don't quite align-yet. But Congress could easily 

change that. There isn't much of a market for carbon dioxide from power plants 

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because the costs of capture typically exceed the market price of carbon dioxide. Oil 

companies might pay $30 or $40 a ton for carbon dioxide, but capturing it from a 

power plant can cost $80 a ton or more. 

So imagine what would happen if the federal government provided a tax credit that 

bridged the difference-a credit, say, of $40 a ton. All of a sudden, we would have a 

market: Oil companies could continue to pay market prices for carbon dioxide, while 

utilities and other industrial sources could make money selling it to them. Instead of 

leaving all that oil underground while carbon continues to accumulate in the 

atmosphere, we could be in the business of sequestering billions of tons of carbon 

dioxide while producing billions more barrels of oil. 

Fine, say the skeptics-but who wants to pay the cost of all those tax credits? New 

subsidies for energy aren't exactly popular on Capitol Hill these days. The difference, 

though, is that an EOR tax credit would more than pay for itself. Over time, its net 

effect on the Treasury would be positive to the tune of tens of billions of dollars. 

Pumping a ton of carbon dioxide into a well produces roughly two-and-a-half to three 

barrels of oil; on average, each barrel generates $23 or so in federal and state taxes 

and royalties (depending on the location and price of the oil, of course). So each ton of 

carbon dioxide used for enhanced oil recovery would create about $58 in revenues. 

Even after covering the cost of a $40 per ton tax credit, the Treasury would come out 

ahead. And when the additional oil production is measured in the billions of barrels, 

the revenues-not even counting the effect of the added oil production on economic 

growth-would be substantial. 

It's worth noting that not all sources of carbon dioxide would require that level of 

subsidy, but power plants are the largest potential supplier of carbon dioxide. And 

over time, as technology and efficiency improve, costs should come down and the 

need for tax incentives should as well. 

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Other public policies could also make EOR more attractive, reducing the need for tax 

credits. Tax-free bonds, for example, would improve the economics of many EOR 

projects; we issue such bonds for many other privately owned pollution-control 

systems but not for carbon capture. Congress could grant that authority, and 

advocates of this concept believe it would make many EOR projects economically 

feasible. 

The EOR industry is going to grow on its own in the coming years, but public policy 

could greatly increase the pace and scale of its expansion. And while the marketfocused mechanisms just described would have the most immediate effect, the shale 

gas model suggests that continued federal support for advanced R&D might be helpful 

as welL 

To maximize the EOR opportunity, public policies should seek to ensure that the 

technologies can be applied widely and that the industry and its markets mature as 

quickly as possible, phasing out the need for financial incentives. Achieving both of 

those goals depends upon the same thing: development and demonstration of nextgeneration EOR technologies that will increase their efficiency and expand their 

applicability in geologically suboptimal conditions. Federal support could speed up 

that process. 

Right now, EOR operations are centered in west Texas in the Permian Basin, in fields 

with very favorable geology. Under such optimal conditions, particularly in higher 

quality fields, the process is efficient: For every metric ton of carbon dioxide injected, 

2.5 barrels of oil are produced. To maximize the market, though, we would want 

companies to be able to operate in more geologically challenging settings such as the 

Rocky Mountains, the Mid-Continent, and second-tier Permian Basin fields. In those 

places, EOR is pricier and less efficient; productivity tends to fall to 2 barrels of oil per 

ton of carbon dioxide injected. 

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How to overcome that? Even modest federal (and/or state) support for research and 

development and, importantly, incentives for demonstration of more efficient EOR 

technologies for these geologically challenging contexts could be very helpful. Will the 

industry get there on its own? Probably, someday-but federal funding would almost 

certainly accelerate that process. 

The issue is not merely maximizing the geographic scope and scale of EOR operations; 

this is also the path to making the markets self-sufficient, which would certainly be in 

the public interest. More efficient next-generation EOR technologies would make 

carbon dioxide more productive and consequently more valuable, reducing the need 

for tax incentives. 

For example: If oil producers in the more challenging Rockies or Gulf Coast oil fields 

are able to recover only two barrels of oil per metric ton of carbon dioxide, and a ton 

of carbon dioxide costs $40, the C02 cost per barrel of oil produced is $20. But nextgeneration technology might make it possible to recover three barrels of oil for every 

ton of carbon dioxide used. That would mean the industry could afford to pay $60 per 

ton of carbon dioxide while keeping its costs constant at $20 per barrel. And as carbon 

dioxide becomes more valuable, tax credits could be phased out. 

If public policies can accelerate the rate at which the industry moves along that cost 

curve-more efficient technologies, bigger markets-the payoff will be enormous. 

Domestic EOR operations now produce about 300,000 barrels of oil a day, but if the 

market took off, they could produce 10 times that amount. 

People will understandably be skeptical of these claims. They've heard too many 

overblown promises from energy and environmental advocates. One important 

attraction of this concept, however, is that it puts the private sector in the role of 

evaluating commercial risks and financing projects; it only costs the government 

money once the process is nearly complete. So if the tax credit fails, it'll fail cheaply. 

To earn the credit, the carbon dioxide would have to be captured and injected into an 

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oil field; at that point, we can be pretty confident that oil is going to be produced as a 

result. If the assumptions about the market effect ofthe tax incentive turn out to be 

wrong and companies don't find it profitable to do EOR, there simply won't be take-up 

on the tax credit; net cost, nothing. 

This sort of public policy decision seems categorically different from government 

bureaucrats placing blind (if not biased) bets on an individual company's ability to 

build a new plant to produce a new commercial product that has to compete in 

complex, ever-changing global markets, as was the case with Obama administration 

missteps such as Solyndra, the now-bankrupt maker of solar panels, and Fisker, the 

failed maker of electric cars. 

Aspects of this concept are, of course, somewhat out of step with the desire for broad 

tax simplification and technology-neutral public policies-but given the lack of 

progress on those fronts, it seems unwise to hold this opportunity hostage to larger 

goals that may never be accomplished. And of course this is not a never-ending 

federal handout to a fundamentally unproductive technology, but a revenue-positive 

tax credit to jump-start a market that would generate trillions of dollars of new 

economic activity based around increased supplies of a commodity that is a linchpin 

of our economy. 

Still, skeptics will rightly wonder why the government should be involved in 

something like this. The answer comes down to the fact that there is a compelling 

public interest at stake in two critical dimensions: Expanding EOR markets could 

arguably do more to improve American energy security-in both transportation and 

electricity-generation fuels-while simultaneously moving us closer to a zeroemissions energy system than any other single policy we could pursue. Even smallgovernment conservatives should be willing to consider policies that leverage such 

significant outcomes out of limited federal interventions, particularly when the 

alternative is an expensive and ineffective regulatory approach to these issues. 

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This last point bears emphasizing: Industrial sources of carbon dioxide such as power 

plants would no longer be just electric generators in this context; they would become 

an integral part of the oil production process. There are places in America where 

there's a lot of oil to be had-if we had carbon dioxide to extract it. An EOR initiative 

would mean that the impetus to install carbon capture on power plants would no 

longer be a politically contentious pollution control measure imposed by Washington; 

instead, it would be a profitable way to harness an essential chemical for oil 

production. 

It's also worth noting that EOR isn't the only way carbon might be productively 

utilized, although it is by far the largest, most reliable near-term opportunity. But 

there are a number of other potential markets for carbon dioxide, ranging from water 

desalination (where its use could cut costs significantly) to the production of 

chemicals, algae bio-fuels, and other commercial products. (In fact, carbon dioxide 

might even be used in fracking itself.) A host of companies are exploring these 

prospects; in October, a $125 million factory opened in Texas that uses a cement 

plant's carbon dioxide to make chemicals. If an EOR initiative created a multibilliondollar market for carbon dioxide, supported by an extensive infrastructure for 

capturing and transporting the gas, these other potential uses of carbon dioxide would 

likely benefit as well. 

It might seem fanciful to imagine that utilization could possibly compare to regulation 

as a tool for reducing carbon emissions, but the numbers suggest otherwise. 

One thing that climate and energy issues have in common: It's all about scale. 

Whether the question is carbon reduction or energy production, it only really matters 

if you're talking about big numbers. So let's look at the potential size of enhanced oil 

recovery. 

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Recall that most "depleted" oil fields still contain a lot of oil. Last year, the leading 

consulting firm in this field, Advanced Resources International, took a fresh look at 

how much oil remains in major deposits in the Lower 48 where EOR might be used 

(and in 2014 extended their analysis, the findings of which are included here). The 

figures are eye-opening. 

Of the 600 billion barrels originally in those reservoirs, 182 billion barrels have been 

produced, and another 22 billion barrels are proven reserves that can be extracted 

economically with existing technologies and practices. That accounts for 204 billion 

barrels, meaning that nearly 400 billion barrels-more than twice the total amount 

produced to date-are "stranded" in these oil fields. 

Advanced Resources International estimates that today's EOR technologies-including 

the next-generation technologies that an EOR initiative could bring to market-would 

make an additional 85.4 billion barrels economical to extract (this assumes oil prices 

at or above $90 a barrel and carbon dioxide prices at or below $40 a ton). 

Those figures are conservative; for one thing, every time new oil fields are discovered, 

these numbers increase. Also, this estimate doesn't factor in the potential to reach into 

"residual oil zones," where oil is typically mixed with water and unavailable through 

conventional means. Residual oil zones contain another 140 billion barrels of oil, 

some significant fraction of which might be accessible using advanced EOR 

technologies. And, of course, if oil prices are higher than $90 a barrel-which, despite 

their recent decline, remains likely in the long run-or if EOR technologies and 

practices improve, then even more oil will become economical to produce. 

Given that America's oil consumption is just under 7 billion barrels a year and 

domestic production is projected to top 3.1 billion barrels in 2014, the opportunity for 

federal policy to unlock access to 85 billion barrels of economical oil-potentially 

producing as much as an additional2 to 3 million barrels of oil per day for the next 50 

years-seems worthy of serious consideration to say the least. 

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The EOR opportunity is much bigger than Keystone XL-and it's American oil, not 

Canadian tar sands. It's bigger than the Arctic National Wildlife Refuge-and it 

involves extracting additional oil from existing fields; even the Natural Resources 

Defense Council approves of enhanced oil recovery as a pragmatic alternative to 

drilling new fields. And it could arguably do more for decarbonization than EPA 

regulations, yet it remains at the margins of the national conversation about energy 

and climate. 

So the numbers are extraordinary on the energy supply side, but what about on the 

carbon reduction side? Democrats aren't likely to support a policy that's just drillbaby-drill; what's in it for them? Here too the tonnage is significant-and the strategic 

implications for decarbonization are even greater than the numbers alone suggest. 

To produce the 85 billion barrels of oil that Advanced Resources International 

estimates EOR could economically reach in the United States, nearly 24 billion tons of 

carbon dioxide would be needed. Geologic (and low-cost industrial) sources might 

provide as much as 3 billion tons but other industrial and agricultural sources of 

carbon dioxide would be needed for the remainder-21 billion tons. When carbon 

dioxide is used in EOR operations, an initial fraction of it (roughly a third) remains 

underground; the rest comes up with the oil, where it can be recaptured and reused 

until it is all sequestered. You could think of EOR as a sophisticated form of carbon 

recycling and disposal. 

lf the only thing an EOR initiative did was to sequester 21 billion tons of carbon 

dioxide, it would still merit serious consideration. But the real measure of success is in 

innovation: What can EOR do to drive development of carbon capture and 

sequestration technologies? 

Because carbon dioxide emissions are cumulative (carbon dioxide accumulates in the 

atmosphere), climate policies can't aspire simply to bend the U.S. emissions curve a 

bit. Stabilizing atmospheric concentrations of carbon dioxide-at any level, on any 

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timeframe-depends on our ability to virtually eliminate emissions from key sectors 

such as electric power generation, and to do it globally. Incremental reductions aren't 

enough; you've got to get to zero. 

Naturally, incremental reductions that reflect real progress toward that goal are 

productive-but not all policies that reduce emissions incrementally lead to zero. 

Natural gas proponents like to call it a "bridge fuel," neatly sidestepping the question 

of what lies on the other side of the bridge or how the two ends connect. Using more 

gas and less coal will lower emissions, but, without carbon capture, the improvement 

is 50 percent at best (and probably less). So if the goal is near-zero emissions, whether 

the fuel is coal or gas, there's no way to get there without carbon capture and 

sequestration. 

Given the extraordinary abundance and affordability of coal and natural gas and the 

enormous established infrastructure for those fuels, pragmatists recognize that there 

is no practical path to decarbonization that doesn't start with the assumption that the 

world is going to continue to burn them for the foreseeable future. Progress on 

decarbonization depends therefore not on dreams of a day when the world agrees to 

leave fossil fuels in the ground but rather on finding practical ways to put their 

carbon dioxide back underground through carbon capture and sequestration, not just 

in advanced economies but also in the developing world. The metric of success for a 

climate policy should not be just the tonnage of avoided annual emissions; the more 

important question is whether we are making decarbonization possible and practical 

on a global scale. 

Here's the thing about carbon capture and sequestration: We know how to do it-but 

it's far from being a mature technology. Capturing carbon dioxide from power plants 

is a challenging business, and doing it on a global scale will require advanced 

technologies and practices, a skilled workforce, robust markets, and extensive 

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infrastructure. It's a long road from here to there. We can see the technology's 

potential, but without a practical path to commercialization, its development will be 

slow. 

Although basic carbon capture and sequestration technologies have been 

demonstrated in varying cont1gurations for decades, companies are only just 

beginning to do carbon capture and sequestration at full scale on power plants 

(including one that just opened in Canada, and another that will open in Mississippi in 

2015). That means the technology is still at the most expensive stage of the learning 

curve, and there is almost no market demand for it today that would drive the 

necessary investments in innovation. 

For carbon capture and sequestration to work well enough for both developed and 

developing nations to use it at scale, the core technologies and their associated 

markets and regulations will need to be much more developed, and costs will have to 

come down considerably. Assessments of the technology strongly suggest that can 

happen-but it will require finding a way to build a lot of these facilities and their 

supporting infrastructure, learn how to operate them efficiently, and learn how to 

build better ones. What is needed most is not just more research (although there's a 

role for that) but rather a way to pay the cost of building carbon capture and 

sequestration projects today at scale-to "learn by doing"-and to create market 

demand for next-generation technologies. 

Regardless of one's stance on climate risks, finding cost-effective ways to develop 

carbon capture and sequestration technologies is important. The EPA's regulatory 

approach won't be the death of coal, but it will bring stagnation and long-term decline 

for the industry. Just the threat of EPA regulations-which will persist for years as the 

regulatory and legal processes play out-will deter the capital investments the 

industry needs to move forward. Over the long run, for coal to continue to serve as 

one of the bedrock fuels for electric generation in America, technologies to manage its 

carbon emissions will be indispensable. Unfortunately, EPA's regulatory proposals 

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look like they may do little, if anything, to drive their development, so if we want to 

find ways to make carbon capture and sequestration work, we'll have to think about 

other approaches. 

Policymakers looking to advance the development of carbon capture and 

sequestration techniques have three basic models at their disposal. 

Option 1 is to have the federal government fund demonstration projects directly. We 

tried that during the George W. Bush administration, which selected a project known 

as FutureGen to be built in Illinois. After more than a decade of delays, that project 

has only just broken ground, so no one is looking to build on that modeL The Bush 

administration also created, and Obama expanded, a Clean Coal Power Initiative that 

has helped fund the few carbon capture and sequestration projects that are getting 

underway-but since it requires a 50 percent cost-share from project developers, it's 

still a far cry from what would be needed to make a significant number of carbon 

capture and sequestration projects economicaL That approach costs taxpayers too 

much while providing project developers too little support. 

Option 2 is the Obama administration's approach: EPA limits on power plant 

emissions. It's anyone's guess what will emerge from the legal, political, and 

bureaucratic battles over EPA's proposed regulations, but one thing is fairly clear. The 

primary effect of whatever regulations survive scrutiny will be to encourage utilities 

to burn more natural gas and less coal, particularly over the next 15 years. This is one 

of the problems with setting modest targets for emissions reductions-industry's 

primary incentive is to seek low-cost compliance options such as fuel-switching rather 

than investing in development of deep decarbonization technologies such as carbon 

capture and sequestration. 

That provides politicians the satisfying appearance of progress-look, we're reducing 

emissions!-while doing little to move us towards commercialization of near-zero 

emissions technologies such as carbon capture. Policies that promote fuel-switching 

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take us on a slightly faster path to a somewhat lower but still-high emissions plateau. 

If we want to get to near-zero emissions from these power plants, we'll need policies 

that specifically target development of carbon capture and sequestration technologies 

and markets. 

Which brings us to option 3, enhanced oil recovery. To provide the 21 billion tons of 

carbon dioxide needed for EOR to reach the 85 billion barrels of economical oil, 

utilities would need to install carbon capture equipment on about 122 gigawatts 

worth of coal-fired power plants (assuming for the sake of simplicity that all the 

carbon dioxide came from power plants-in fact, some would come from other 

sources). That would mean putting carbon capture and sequestration on roughly half 

ot'the coal plants expected to be in operation over the next 30 years (taking 

anticipated plant retirements into account). 

The significance of that figure can hardly be overstated. EPA regulations aren't going 

to put carbon capture and sequestration on half the coal fleet-not even close. Federal 

demonstration projects and grants certainly won't. EOR demand could generate over 

$800 billion in revenue from carbon dioxide sales, much of which could be invested in 

developing and operating the infrastructure of carbon capture and transportation. 

Where else is that level of investment going to come from? 

EOR's revenues offer what is almost certainly the only practical path to making the 

investments necessary to demonstrate carbon capture and sequestration technologies 

at scale, build out supporting infrastructure, and develop the legal, financial, 

commercial, and institutional structures and relationships that would make the 

industry a credible option for decarbonization. And a policy push for EOR would put 

American companies at the forefront of another energy revolution, just as they are 

with fracking, with the opportunity to sell technologies and services in potentially vast 

global markets. 

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The best evidence for EOR's potential to drive carbon capture and sequestration 

development is that it's doing so already, even without the benefit of strong federal 

support. Every new carbon capture and sequestration project underway or recently 

opened in North America-Southern Company's Kemper project in Mississippi, a new 

power plant with carbon capture and sequestration; SaskPower's Boundary Dam 

project retrofitting carbon capture and sequestration to an existing coal-fired power 

plant in Saskatchewan, Canada; and NRG Energy's newly announced W. Parish project 

near Houston-relies heavily on EOR revenues (as well as government grants). 

Because of the location of the plant, NRG is also able to take advantage of tax-free 

bonding of the kind that could help other EOR projects. 

Having said that EOR's potential to drive carbon capture and sequestration could 

hardly be overstated, I should make sure that I haven't done just that. EOR is a way to 

instigate and pay for the development of advanced carbon capture and sequestration 

technologies and infrastructure, as well as the legal, governmental, and commercial 

structures necessary for the industry to thrive. The size of the EOR opportunity will 

probably increase over time. But recycling carbon into oil production and other 

products won't solve the carbon dioxide issue entirely. EOR markets might cover the 

costs of sequestering an awful lot of carbon dioxide for a long time-but not forever. 

Some day, policy-makers would have to revisit the question of how much they might 

be willing to pay to continue sequestration. 

But by that time, they wouldn't be fighting a pitched battle over whether a federal 

agency can and should impose regulations requiring the use of an immature 

technology that is not yet proven on a commercial scale, where the price and 

performance of the technology remain uncertain and daunting. Instead, they would 

be making a well-informed decision about the continued use of a highly refined 

technology with well-understood costs and performance characteristics that is 

supported by an extensive, sophisticated physical and commercial infrastructure. By 

that point, costs of sequestration should be dramatically lower than they are today. 

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We can't know how much society might value decarbonization in the future, we can 

only work on finding practical ways to develop tools that could do the job, recognizing 

that the lack of such options is the primary source of political conflict over carbon 

today. Instead of placing blind bets on Rube Goldberg regulatory schemes resting on 

creative interpretations of outdated laws and a host of farfetched assumptions, 

climate advocates would be asking governments to make informed choices about 

using proven, affordable technologies. That would be a very different 

conversation. 

One other issue requires consideration: the emissions from burning the oil that 

enhanced oil recovery would produce. To many environmentalists, using carbon to 

produce more fossil fuels could hardly be more perverse. How does this get us ahead? 

This is, unfortunately, a very complex question. Let me sketch the outlines of an 

answer. 

Emissions from transportation and from generating electricity are in a sense almost 

entirely separate issues. In both sectors, decarbonization using to day's technologies is 

impractical; success depends on developing innovative technologies with far better 

price and performance than we have today. If we want decarbonization options for 

electric power, we need policies that will develop those technologies; if we want better 

transportation options, we need polices that target those technologies. 

Enhanced oil recovery. as l have argued, is the only realistic path to developing 

carbon capture and sequestration technologies, which will be needed for 

decarbonizing electric generation. Decarbonizing transportation systems is mostly a 

different question-although it's worth noting that carbon capture and sequestration 

is also essential for low-carbon transportation options such as electrification and 

some alternative fuels. 

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The important thing to appreciate is that the development of those transportation 

technologies is not going to be hindered by the production of another 60 or 80 or even 

100 billion barrels of oil in the United States. Those technologies will rise or fall on 

their merits, and when they can compete with conventional cars and trucks and 

buses, they'll win; the marginal effect that EOR will have on the price and production 

of oil won't hinder that process. 

That's a conceptual answer to the question, but some people will want to understand 

the math as well: Will producing more oil in America using EOR increase or decrease 

carbon dioxide emissions? 

The long-term answer to that depends not on simple carbon-in, carbon-out arithmetic 

but on one's assumptions about EOR's influence on the oil and electric power markets. 

If one thinks of EOR's oil as additive-additional oil that would otherwise not be 

consumed-and doesn't take into account the displacement of more carbon-intensive 

electric power by carbon capture and sequestration, then EOR could release more 

carbon dioxide than it eliminates. But if you believe that oil produced by EOR will 

mostly displace imported oil, and that low-carbon electricity from carbon capture and 

sequestration will displace higher-carbon power-which seems likely, at least to some 

extent-then EOR will sequester more carbon dioxide than it produces. 

To give an example of the complexity of the calculations: Critics of EOR often cite a 

2009 study by Carnegie Mellon's Paulina Jaramillo {with coauthors W. Michael Griffin 

and Sean T. McCoy), which concluded that each ton of carbon dioxide injected in EOR 

operations produces oil that releases 3. 7 to 4. 7 tons of carbon dioxide emissions. 

Sounds pretty bad, right? But that figure assumes the oil and electricity from EOR are 

added to what's already available; naturally, that means net emissions increase. If you 

incorporate the more realistic assumption that the oil and electricity produced by EOR 

and carbon capture and sequestration would displace other energy from the market, 

Jaramillo concedes that EOR reduces net emissions by about 20 percent, a figure that 

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rises to 30 percent when compared with Canadian tar sands oil and new coal plants. 

The National Environmental Technology Laboratory (NETL) also looked at this 

question last year and came to similar conclusions (although their figure for EOR's 

additive emissions is 1.7 tons of carbon dioxide, a much lower figure than 

Jaramillo's). 

These studies are far from perfect-answers to these questions depend on long-term 

projections about the behavior of oil and electricity markets during periods of 

significant change-but the broad picture they paint is probably not far from the 

mark. 

Here's a simpler way to think about this question in present-day terms: A barrel of oil 

contains 0.43 metric tons of carbon dioxide. As mentioned previously, current EOR 

operations in the Permian Basin use 0.4 metric tons of carbon dioxide per barrel of oil 

recovered; even without taking displacement into account, that process is essentially 

carbon neutral. Add in the displacement of conventional oil and we are well on our 

way to net sequestration. 

One can think of the combination of enhanced oil recovery with carbon capture and 

sequestration as providing low-carbon power or low-carbon-dioxide oil, or arguably 

both, but certainly not neither. EOR's direct effect on carbon dioxide emissions may be 

somewhat uncertain, but at worst it's a wash, and more likely it sequesters more 

carbon than it produces. What is indisputable is the progress it could provide toward 

the metric that matters most: EOR is the only plausible way to pay for the 

development of advanced carbon capture and sequestration technologies and the 

billions of dollars of infrastructure investments that will be necessary to make the 

technology a workable option for controlling carbon dioxide emissions from fossil 

fuels. 

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Whatever one concludes about the direct sequestration question, anyone who is 

serious about practical decarbonization pathways cannot afford to ignore EOR. It's 

difficult to compare EOR's direct annual emissions reductions to the possible effects of 

EPA's regulatory proposals, but if our ultimate goal is a practical pathway to 

commercialization of carbon capture and sequestration, the potential power of 

markets for carbon dioxide utilization cannot be denied. 

Carbon utilization is not receiving nearly the attention it deserves. We should be 

having a national conversation about enhanced oil recovery; instead, we are obsessed 

with issues that are almost trivial in comparison. The basic facts of the matter seem 

clear: Carbon capture and sequestration is probably indispensable to any pragmatic 

approach to decarbonization, and EOR appears to be the only practical way to 

underwrite the extensive up-front costs of developing carbon capture and 

sequestration technologies, infrastructure, and markets. 

Using carbon capture and sequestration to enable enhanced oil recovery is the path to 

keeping coal in our energy economy while simultaneously achieving our 

environmental goals; without it, we are likely to lose both battles. The choice is 

between a declining-but-not-disappearing coal industry that can't invest in innovation 

and a thriving, productive industry that could develop effective carbon management 

technologies. EOR could produce tens of billions of barrels of oil in America while 

sequestering billions of tons of carbon dioxide and driving over $800 billion in 

investments in decarbonization and energy production technologies. And it would 

establish a different model for meeting the climate challenge: Make decarbonization 

technologies affordable and productive rather than trying to make carbon-intensive 

energy more expensive. 

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A national enhanced oil recovery initiative wouldn't entirely protect America from 

the vagaries of global oil markets or fully eliminate carbon dioxide emissions from 

our electric power plants-but it would make genuine, important progress on both 

fronts, and that would be no small feat. 

Samuel Thernstrom, a senior fellow at the Center for the National Interest, is the 

founder and executive director 

of the Energy Innovation Reform Project (innovationreform.org). He participates in a 

bipartisan coalition that advocates for an expansion of federal incentives for 

enhanced oil recovery 

Web link: http://www.weeklystandard.com/article/821866 

John Kelly In, Reince 

Priebus Out as White 

House Chief of Staff 

President Trump announces the latest White House shakeup with a Friday afternoon tweet. 

5:40 PM, JUL 28, 2017 I By ANDREW EGGER 

President Donald Trump announced the latest White House shakeup via Twitter on 

Friday afternoon, tweeting that John F. Kelly would replace Reince Preibus as White 

House chief of staff. 

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Donald J. Trump 

@realDona!dTrump 

I am pleased to inform you that I have just 

named General/Secretary John F KeiJy as 

White House Chief of Staff. He is a Great 

American .. , 

4:49PM- Jul28, 2017 

?4 4RG 

Donald J. Trump 

@reaiDona!dTruntp 

Q? 

... and a Great Leader. John has also 

done a spectacular job at Homeland 

Security. He has been a true star of my 

Administration 

4:54PM· Jul 28, 2017 

7 h7? 

The move follows months of speculation that Priebus was not long for the job, which 

grew to a fever pitch when Trump took on rival Anthony Scaramucci as his 

communications director last week. Priebus successfully convinced Trump not to give 

Scaramucci a role in his administration in January. 

Priebus, the former three-term chair of the Republican National Committee, struggled 

to bring order and unity to Trump's chaotic White House.* Priebus reportedly 

resigned privately on Thursday, according to sources with knowledge of Priebus' 

conversations with Trump. 

The president has grown obsessed in recent months with White House information 

leaking into the press, and Scaramucci is convinced Priebus has been responsible. The 

new comms director viciously attacked Priebus, calling him "a f-ing paranoid 

schizophrenic" in a conversation with the New Yorker's Ryan Lizza. 

"Oh, Bill Shine is coming in," Scaramucci said to Lizza, imitating Priebus. "Let me leak 

the f---ing thing and see if I can cock-block these people the way I cock-blocked 

Scaramucci for six months." 

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Kelly, Priebus's replacement, is a retired Marine Corps general and the former 

commander of the U.S. Southern Command. As Secretary of Homeland Security, he 

has ferociously advocated for Trump's agenda, most notably by advocating for the 

complete construction of the U.S.-Mexican border wall within two years. 

Kelly has also repeatedly demonstrated the personal loyalty Trump craves by 

defending the administration's conduct on television. In March, when Trump 

baselessly accused Barack Obama of ordering him wiretapped, Kelly said Trump must 

llilYJ;, "some convincing evidence that took place." In May, Kelly defended Trump's sonin-Jaw Jared Kushner after it was reported that Kushner had attempted to set up a 

back channel to communicate with Russia. 

"There's a lot of different ways to communicate, back channel publicly with other 

countries," Kelly said. "I don't see any issue here relative to Jared." 

Web link: http://www.weeklystandard.com/article/2009057 

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