{"id":273186,"date":"2023-08-13T12:10:43","date_gmt":"2023-08-13T10:10:43","guid":{"rendered":"https:\/\/climatescience.press\/?p=273186"},"modified":"2023-08-13T12:10:57","modified_gmt":"2023-08-13T10:10:57","slug":"comments-on-the-insanity-of-epas-new-power-plant-rule","status":"publish","type":"post","link":"https:\/\/climatescience.press\/?p=273186","title":{"rendered":"Comments On The Insanity Of EPA’s New Power Plant Rule"},"content":{"rendered":"\n
\"\"<\/figure>\n\n\n\n

<\/p>\n\n\n\n

From The MANHATTAN CONTRARIAN<\/a><\/p>\n\n\n\n

By Francis Menton<\/a><\/p>\n\n\n\n

On May 23, EPA put out its long-expected proposed Rule designed to eliminate, or nearly so, all so-called \u201cgreenhouse gas\u201d emissions from the electricity-generation sector of the economy.\u00a0 The proposal came with the very long title: \u201cNew Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.\u201d<\/a>\u00a0 The full document is 672 pages long. \u00a0\u00a0<\/em><\/strong><\/p>\n\n\n\n

Various not-very-far-off deadlines are set, ranging from as early as 2030 for some changes to coal plants, to at the latest 2038 for the last changes to natural gas plants.\u00a0 But how exactly is this emissions elimination thing to be accomplished?\u00a0 Today a substantial majority of U.S. electricity (about 60%) comes from one or the other of those fuels; and it is inherent in the burning of hydrocarbons that you get CO2 as a product.\u00a0 In all those 672 pages, EPA has only two ideas for how to eliminate the carbon emissions from combustion power plants: carbon capture and storage (CCS), and \u201cgreen\u201d hydrogen.\u00a0 Either you must implement one of those two ideas to meet EPA\u2019s standards by the deadline, or you must close your power plant.\u00a0 But here\u2019s the problem: both of those ideas are, frankly, absurd.\u00a0 \u00a0<\/em><\/strong><\/p>\n\n\n\n

The deadline for commenting on the proposed Rule was August 8, although comments have continued to pile in after that date.\u00a0 Many hundreds of them have been received.\u00a0 If you have nothing else to do for the next month or two, you can review the comments at this link<\/a>.\u00a0<\/p>\n\n\n\n

I have by no means made the effort to read all the comments, but I have gone looking for some of the more significant ones.\u00a0 Two that I can highly recommend are this one<\/a> by a group of 21 red state AGs led by West Virginia, and this one<\/a> by an overlapping group of 18 red state AGs led by Ohio.\u00a0 Both of those comments do an excellent job of dismantling the concept that either CCS or \u201cgreen\u201d hydrogen could ever work as a significant part of our electricity generation system.\u00a0 Of the two, the West Virginia comment is the much longer (54 pages) and goes into far more technical detail.\u00a0 But the Ohio comment, at 21 pages, has its share of good zingers as well.<\/p>\n\n\n\n

The Ohio and West Virginia comments label the idea of CCS at the high rate demanded by EPA (90%) as either \u201cinfeasible\u201d or not \u201cviable,\u201d and include recitations of the history of failed attempts to implement this frankly useless technology.\u00a0 From the Ohio comment (page 4):<\/p>\n\n\n\n

A study of 263 carbon-capture-and-sequestration projects undertaken between 1995 and 2018 found that the majority failed and 78% of the largest projects were cancelled or put on hold.\u00a0 After the study was published in May 2021, the only other coal plant with a carbon-capture-and-sequestration attachment in the world, Petra Nova, shuttered after facing 367 outages in its three years of operation.<\/em><\/p>\n\n\n\n

With the closure of Petra Nova, there remains in the entire world exactly one operating commercial CCS facility at a coal power station, the SaskPower Boundary Dam Unit 3 in Saskatchewan, Canada.\u00a0 That one is supposed to achieve the 90% capture rate that EPA demands, but with constant operating issues it has fallen way, way short:<\/p>\n\n\n\n

[T]his [SaskPower] facility is the world\u2019s only operating commercial carbon capture facility at a coal-fired power plant.\u00a0 \u00a0And it has never achieved its maximum capacity.\u00a0 It also battled significant technical issues throughout 2021\u2014to the point that the plant idled the equipment for weeks at a time.\u00a0 As a result, the plant achieved less than 37% carbon capture that year despite having an official target of 90% . . . .\u00a0<\/em><\/p>\n\n\n\n

The West Virginia comment provides lots more technical detail on the failures of CCS. Why can\u2019t a CCS system just easily suck up all the CO2 out of a power plant\u2019s emissions stream? Because the effort to suck up the emissions takes energy from the output of the plant, and the higher the percentage of carbon emissions you seek to capture, the more of the energy output of the plant you consume. (I have previously described CCS efforts as a \u201cwar against the second law of thermodynamics.\u201d). In the limiting case, you can use up all the power output of the plant on the CCS system and still not capture 100% of the CO2. From the West Virginia comment, page 24-25:<\/p>\n\n\n\n

Take efficiency to start. CCS units run on power, too. An owner can get that power from the plant itself. But this approach makes the plant less efficient by increasing its \u201cparasitic load\u201d\u2014and CCS more than triples combustion turbines\u2019 normal parasitic load. . . . This is the cause the Wyoming study analyzed that showed installing CCS technology would devastate plants\u2019 heat rates and lower net plant efficiency by 36%.<\/em><\/p>\n\n\n\n

And that percentage relates to a system that captures well less than 100% of the plant\u2019s carbon emissions. And these are only the start of the technical issues to be faced. For example, once you have captured all this CO2, where do you put it? Do you build an entire new national network of pipelines (at a cost of hundreds of billions of dollars) to transport it to some underground caverns somewhere? And then, are there environmental issues with the chemicals used to snag the CO2 out of the power plant\u2019s emissions stream? From the West Virginia comment, page 27:<\/p>\n\n\n\n

The Proposed Rule would force utilities to adopt and communities to accept all aspects of CCS technology without fully understanding the ramifications. For example, the environmental and health effects of CANSOLV\u2014the leading amine-based and EPA-recommended CCS solvent, 88 Fed. Reg. at 33,291\u2014appear unknown; leading CANSOLV studies over the past decade don\u2019t discuss its impact.<\/em><\/p>\n\n\n\n

And then, if you have to increase the power output of the plant by 50% or so to power the CCS facility, doesn\u2019t that then increase the emissions of nitrous oxides and particulates by a comparable amount? From the West Virginia comment, page 27:<\/p>\n\n\n\n

Nearly a decade ago, the European Union\u2019s European Environmental Agency released a study finding that CCS would increase \u201cdirect emissions of NOx and PM\u201d by nearly a half and a third, respectively, because of additional fuel burned, and increase \u201cdirect NH3 emissions\u201d \u201csignificantly\u201d because of \u201cthe assumed degradation of the amine-based solvent.\u201d<\/em><\/p>\n\n\n\n

It goes on and on from there. And then there\u2019s the idea of \u201cco-firing\u201d the power plants with \u201cgreen\u201d hydrogen, produced by using wind or solar power or something else magical to electrolyze water. EPA\u2019s proposed Rule would impose such a requirement on existing natural gas plants to take them up to 96% hydrogen by 2038. A few insights from the West Virginia comment, page 35:<\/p>\n\n\n\n

Most combustion turbines on the market today cannot handle anything more than a 5-10% blend [of hydrogen]; 20% is generally accepted as the absolute technological ceiling. . . . Even in the best scenarios, a hydrogen volume fraction of 20% is usually the most technology currently can do.<\/em><\/p>\n\n\n\n

And how about the problem (and cost) of producing the amounts of hydrogen that would be required. From the West Virginia comment, page 37:<\/p>\n\n\n\n

America currently produces just .5% of the clean hydrogen we need under the Proposed Rule. The industry would have to close a 99.5% supply gap in just 15 years. EPA has offered no evidence showing that this gap will close.<\/em><\/p>\n\n\n\n

There is much, much more on issues like transporting and handling the hydrogen, cost of production, and so forth.<\/p>\n\n\n\n

The conclusion is obvious and impossible to escape: These proposed methods to allow combustion power plants to continue to exist are not real and can never work. EPA intends to force the closure of all such electricity generation facilities. Will we have an electricity system that can still function at that point? They neither know nor care. After all, we have a planet to save here.<\/p>\n\n\n\n

Somehow, in the weighing of the costs and benefits here, the bureaucrats appear to have completely lost track of the enormous benefits that reliable access to electricity has brought to the people. They will destroy that without giving the subject a second thought.<\/p>\n\n\n\n

<\/p>\n\n\n\n

<\/p>\n","protected":false},"excerpt":{"rendered":"

On May 23, EPA put out its long-expected proposed Rule designed to eliminate, or nearly so, all so-called \u201cgreenhouse gas\u201d emissions from the electricity-generation sector of the economy.\u00a0 The proposal came with the very long title: \u201cNew Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.\u201d\u00a0 <\/p>\n","protected":false},"author":121246920,"featured_media":273194,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_coblocks_attr":"","_coblocks_dimensions":"","_coblocks_responsive_height":"","_coblocks_accordion_ie_support":"","advanced_seo_description":"","jetpack_seo_html_title":"","jetpack_seo_noindex":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2},"jetpack_post_was_ever_published":false},"categories":[1],"tags":[691821807,691818076,691818073],"class_list":["post-273186","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-uncategorized","tag-carbon-capture-and-storage-ccs","tag-co2","tag-epa","fallback-thumbnail"],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/08\/image-511.png?fit=1024%2C1024&ssl=1","jetpack_likes_enabled":true,"jetpack_sharing_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/paxLW1-194e","jetpack-related-posts":[{"id":282674,"url":"https:\/\/climatescience.press\/?p=282674","url_meta":{"origin":273186,"position":0},"title":"Electric Grid Reliability: Texas vs. EPA","author":"uwe.roland.gross","date":"10\/10\/2023","format":false,"excerpt":"A Home Depot parking lot is covered in snow in the Westbury neighborhood, Monday, Feb. 15, 2021, in Houston. From \u00a0Master Resource By Ed Ireland \u201cJust the possibility that EPA will enact such sweeping regulations will slow investment in new power generation that all U.S. power grids need. Recent grid\u2026","rel":"","context":"In \"CO2\"","block_context":{"text":"CO2","link":"https:\/\/climatescience.press\/?tag=co2"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/10\/00rawImage.jpg?fit=1200%2C900&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/10\/00rawImage.jpg?fit=1200%2C900&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/10\/00rawImage.jpg?fit=1200%2C900&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/10\/00rawImage.jpg?fit=1200%2C900&ssl=1&resize=700%2C400 2x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/10\/00rawImage.jpg?fit=1200%2C900&ssl=1&resize=1050%2C600 3x"},"classes":[]},{"id":257019,"url":"https:\/\/climatescience.press\/?p=257019","url_meta":{"origin":273186,"position":1},"title":"EPA proposes emissions standards that could kill coal, and cripple gas OFFICIAL EPA RELEASE","author":"uwe.roland.gross","date":"05\/12\/2023","format":false,"excerpt":"As China and India build coal plants as fast as their economies will go, the Biden Administration released plans to require carbon capture using unaffordable technology that does not really exist.\u00a0 Will this carbon power grab survive judicial review?\u00a0","rel":"","context":"In \"CCS\"","block_context":{"text":"CCS","link":"https:\/\/climatescience.press\/?tag=ccs"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/05\/00fairfaxphotos-Coal.webp?fit=1140%2C758&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/05\/00fairfaxphotos-Coal.webp?fit=1140%2C758&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/05\/00fairfaxphotos-Coal.webp?fit=1140%2C758&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/05\/00fairfaxphotos-Coal.webp?fit=1140%2C758&ssl=1&resize=700%2C400 2x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2023\/05\/00fairfaxphotos-Coal.webp?fit=1140%2C758&ssl=1&resize=1050%2C600 3x"},"classes":[]},{"id":383925,"url":"https:\/\/climatescience.press\/?p=383925","url_meta":{"origin":273186,"position":2},"title":"EPA Gets Moving On Its Push For Energy Deregulation","author":"uwe.roland.gross","date":"06\/20\/2025","format":false,"excerpt":"Now coming into view are the specifics of EPA\u2019s strategy to end the Obama\/Biden efforts to strangle the energy sector of the economy in the name of \u201csaving the planet\u201d from climate change. A document released by EPA last week on June 11 lays out the plan for repeal of\u2026","rel":"","context":"In \"carbon dioxide (CO\u2082)\"","block_context":{"text":"carbon dioxide (CO\u2082)","link":"https:\/\/climatescience.press\/?tag=carbon-dioxide-co%e2%82%82"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/06\/2GR-RENDER1-1536x869-1.png?fit=1200%2C679&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/06\/2GR-RENDER1-1536x869-1.png?fit=1200%2C679&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/06\/2GR-RENDER1-1536x869-1.png?fit=1200%2C679&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/06\/2GR-RENDER1-1536x869-1.png?fit=1200%2C679&ssl=1&resize=700%2C400 2x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/06\/2GR-RENDER1-1536x869-1.png?fit=1200%2C679&ssl=1&resize=1050%2C600 3x"},"classes":[]},{"id":426214,"url":"https:\/\/climatescience.press\/?p=426214","url_meta":{"origin":273186,"position":3},"title":"Trump Administration Ends Obama-Era Climate Finding, Repeals Vehicle GHG Standards","author":"uwe.roland.gross","date":"02\/14\/2026","format":false,"excerpt":"On February 12, 2026, the U.S. Environmental Protection Agency (EPA), under Administrator Lee Zeldin and alongside President Trump, finalized a major rule that revokes the 2009 Greenhouse Gas Endangerment Finding, a landmark Obama-era determination that greenhouse gases (GHGs) like carbon dioxide endanger public health and welfare. This finding had served\u2026","rel":"","context":"In \"Biden and Obama administrations\"","block_context":{"text":"Biden and Obama administrations","link":"https:\/\/climatescience.press\/?tag=biden-and-obama-administrations"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/0Screenshot-2026-02-12-184328-1.png?fit=1033%2C937&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/0Screenshot-2026-02-12-184328-1.png?fit=1033%2C937&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/0Screenshot-2026-02-12-184328-1.png?fit=1033%2C937&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/0Screenshot-2026-02-12-184328-1.png?fit=1033%2C937&ssl=1&resize=700%2C400 2x"},"classes":[]},{"id":427608,"url":"https:\/\/climatescience.press\/?p=427608","url_meta":{"origin":273186,"position":4},"title":"Climate alarmists howl after EPA rescinds \u2018Endangerment Finding\u2019","author":"uwe.roland.gross","date":"02\/23\/2026","format":false,"excerpt":"The US Environmental Protection Agency has finally\u00a0rescinded the 2009 Endangerment Finding\u00a0(EF) \u2013 the Obama era EPA ruling that claimed carbon dioxide and other \u201cgreenhouse gas\u201d (GHG) emissions \u201cendanger\u201d human health and welfare. Within minutes, climate alarmists challenged it in court.","rel":"","context":"In \"2009 Endangerment Finding (EF)\"","block_context":{"text":"2009 Endangerment Finding (EF)","link":"https:\/\/climatescience.press\/?tag=2009-endangerment-finding-ef"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/Screenshot-2026-02-12-184328.png?fit=1033%2C937&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/Screenshot-2026-02-12-184328.png?fit=1033%2C937&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/Screenshot-2026-02-12-184328.png?fit=1033%2C937&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2026\/02\/Screenshot-2026-02-12-184328.png?fit=1033%2C937&ssl=1&resize=700%2C400 2x"},"classes":[]},{"id":402324,"url":"https:\/\/climatescience.press\/?p=402324","url_meta":{"origin":273186,"position":5},"title":"Trump Admin Moves To Blow Up Greenhouse Gas Reporting Program (GHGRP)","author":"uwe.roland.gross","date":"09\/15\/2025","format":false,"excerpt":"The Trump administration is moving to scrap an Environmental Protection Agency (EPA) program projected to save American businesses up to $2.4 billion in regulatory costs, according to the agency.","rel":"","context":"In \"carbon dioxide (CO\u2082)\"","block_context":{"text":"carbon dioxide (CO\u2082)","link":"https:\/\/climatescience.press\/?tag=carbon-dioxide-co%e2%82%82"},"img":{"alt_text":"","src":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/09\/0EPA-Building-Plaque.jpg?fit=1200%2C803&ssl=1&resize=350%2C200","width":350,"height":200,"srcset":"https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/09\/0EPA-Building-Plaque.jpg?fit=1200%2C803&ssl=1&resize=350%2C200 1x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/09\/0EPA-Building-Plaque.jpg?fit=1200%2C803&ssl=1&resize=525%2C300 1.5x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/09\/0EPA-Building-Plaque.jpg?fit=1200%2C803&ssl=1&resize=700%2C400 2x, https:\/\/i0.wp.com\/climatescience.press\/wp-content\/uploads\/2025\/09\/0EPA-Building-Plaque.jpg?fit=1200%2C803&ssl=1&resize=1050%2C600 3x"},"classes":[]}],"_links":{"self":[{"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/posts\/273186","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/users\/121246920"}],"replies":[{"embeddable":true,"href":"https:\/\/climatescience.press\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=273186"}],"version-history":[{"count":8,"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/posts\/273186\/revisions"}],"predecessor-version":[{"id":273195,"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/posts\/273186\/revisions\/273195"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/climatescience.press\/index.php?rest_route=\/wp\/v2\/media\/273194"}],"wp:attachment":[{"href":"https:\/\/climatescience.press\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=273186"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/climatescience.press\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=273186"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/climatescience.press\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=273186"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}