Air Pollution Control Equipment Services, Combined Cycle, Policy & Regulations

CCS: A Tale of Federal Discombobulation

Issue 4 and Volume 119.

“Obituary. FutureGen2.0, Washington, D.C. (2003-2015). Cause of death: suffocation. No funeral planned. The family requests no flowers. Donations suggested to the Dept. of Energy.”

In February 2015, the Department of Energy (DOE) killed the FutureGen2.0 project by withdrawing $1 billion in federal stimulus funds. Born in 2003, FutureGen2.0 was supposed to be the most comprehensive carbon capture and sequestration (CCS) demonstration project, combining all three aspects of CCS technology: capturing and separating carbon dioxide (CO2) from other gases, compressing and transporting CO2 to the sequestration site, and injecting CO2 in geologic formations for permanent storage. What does this mean for the future of CCS?

The federal government has been one of the most vocal proponents of CCS, as seen in EPA’s recently proposed rule addressing Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units [aka the Clean Power Plan (CPP)]. The draft rule claims that the “partial implementation” of CCS is the Best System of Emission Reduction (BSER) for new coal-fired boilers and integrated gasification combined cycle (IGCC) units. The draft rule cites the FutureGen project as an example CCS demonstration project that supports EPA’s conclusion of CCS as BSER for utility boilers and IGCC units.

For natural gas combined cycle turbines (NGCC) the draft CPP states that CCS is not the best system of emission reduction for a nationwide standard based on questions about whether full or partial capture CCS is technically feasible for the NGCC source category. However, in recent Prevention of Significant Deterioration (PSD) applications for both simple- and combined-cycle gas turbine projects, EPA has insisted that CCS is “technically feasible” unless ruled out on each specific permitting action. “Technically feasible” and “economically feasible” have specific regulatory meanings in a PSD analysis. EPA and state agencies actively encourage applicants to eliminate CCS during Step 4 of the Best Available Control Technology Analysis (BACT), which allows consideration of economic, energy, and environmental impacts. U.S. Energy Information Administration office estimates (see in Table) show that adding CCS to a new NGCC facility at least doubles the capital cost. It is unclear whether these CCS cost estimates include pipeline costs, but for recent PSD permits, EPA estimated that adding separate pipeline construction costs would increase the CCS costs by 1-5%.

Updated Estimates of Power Plant Capital and Operating Costs

Plant Type

Plant Cost (2012$)/kW


Without CCS

With CCS

Single Advanced Pulverized Coal



Dual Advanced Pulverized Coal



Single IGCC



Advanced Combined Cycle



Source: U.S. Department of Energy, U.S. Energy Information Administration, Updated Capital Cost Estimates for Utility Scale Electricity Generating Plants (April 2013) (DOE Report).

A major revision from the CPP initial proposal to the current draft rule is the acknowledgement that CCS is not the only solution. Instead of a single standard and a single BSER determination for all new fossil fuel-fired units, the current draft rule breaks natural gas combined cycle (NGCC) turbines apart from fossil fuel-fired electric steam generating units.

If CCS is required for new coal-fired boilers and the DOE acknowledges that CCS might not be practical for facilities such as FutureGen, then it is reasonable to conclude that the Clean Power Plan is written to specifically prevent new coal-fired boilers and not just to implement the best system of emission reduction.

EPA considers CCS to be technically feasible in general, technically infeasible in specific cases, and universally just too expensive. So why is it still the foundation for the proposed Clean Power Plan? The answer will undoubtedly be determined by the courts.