Performance Standards and Regulations

Performance standards must be developed to drive CCS deployment and to provide planning certainty for emitters, financial institutions, and utility regulators. In addition, they would serve as a backstop to the uncertainty inherent in CO₂ allowance price markets under cap and trade programs.

Coal plants permitted today should match the emission standards of a natural gas plant. By 2025 new coal and gas plants should meet the equivalent emissions standard of a 90% reduction—an emissions profile that, by 2040, all fossil plants should match. More specifically:

• New coal plants permitted between 2009 and 2025 should be limited to emissions between 770 and 1,100 lbs. per megawatt hour.
• New coal plants permitted in 2025 should meet a standard of 275 lbs. per megawatt hour.
• New gas plants permitted in 2025 should meet a standard of 100 lbs. per megawatt hour.
• Coal and gas plants permitted before 2025 should meet a standard of 300 lbs. per megawatt hour by no later than 2040.
• Performance standards needed to address other pollutants including sulfur dioxide, nitrogen oxide, and mercury.

These standards must be implemented with substantial and well-designed financial support, funded through CO₂ proceeds or allowance value from the climate bill. The incentives must scale-up a new commercial CCS industry—targeting 150 megawatts of new and existing coal and gas projects.

Federal policy must include adequate safeguards for injection and monitoring sequestered CO₂. Longstanding groundwater protection regulations are in effect for enhanced oil recovery (EOR), but sequestration projects will have much higher volumes and greater injection pressures. In addition, while groundwater protection is a good proxy for preventing leakage out of the sub-surface and back into the atmosphere, additional regulations will be necessary to verify sequestration and remediate any problems that might occur over the long term. To meet the objective:

• EPA must finalize a strong new groundwater protection rule for sequestration. CATF provided comments to EPA’s proposed Class VI rule for geologic carbon sequestration.
• Beyond groundwater protection, EPA must develop regulations that address preventing CO₂ leakage from the subsurface and back into the atmosphere. CATF offered comments on pending rules related to such protections.