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completed, but none of these is currently operational, and several planned
projects have been abandoned for a variety of reasons. 22
Should Cost and/or Energy Considerations Have Led EPA
to Propose a Less Stringent Standard?
Although it maintains that CCS has been adequately demonstrated, EPA
concedes, based on DOE estimates, that ―using today's commercially available
CCS technologies would add around 80 percent to the cost of electricity for a
new pulverized coal (PC) plant, and around 35 percent for a new advanced
gasification-based (IGCC) plant.‖ 23 The Congressional Budget Office, in a
June 2012 report, reached essentially the same conclusion. 24 Much of this
increased cost results from what is termed a ―parasitic‖ energy load: capturing
CO 2 , compressing it, transporting it, and injecting it underground would use as
much as 30% of the electricity that a coal-fired plant produces.
Both EPA and the Congressional Budget Office, among others, assume
that the cost and energy penalty can be reduced through research,
development, and demonstration, and both view EPA regulation as one of the
policy tools that could lead to reduced cost by forcing the development of
better technology. Experience suggests that such ―learning by doing‖ will
lower the cost, but the road to what might be a competitive technology is a
long one, and given the availability of other power sources (such as natural
gas, renewables, and nuclear) with lower or no carbon emissions, it is not clear
that the electric power industry will be motivated to pursue it.
Despite the potentially high cost of currently available CCS technology,
the agency ―does not anticipate this rule will have any impacts on the price of
electricity, employment or labor markets, or the US economy.‖ 25 Other than
―transitional‖ coal-fired units exempt from the proposed standard and
demonstration projects supported by DOE or other incentives, no new coal-
fired units will actually use CCS in the next 10 years: given the low cost and
projected abundance of natural gas, all new fossil-fueled units are likely to be
powered by gas, according to EPA.
Forecasts suggesting that new coal is unlikely to be built by 2020
have been shown to be robust under a range of alternative assumptions
that influence the industry's decisions to build new power plants. For
example, EIA typically supplements the AEO [Annual Energy Outlook]
with a series of distinct scenarios that explore specific issues and examine
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