Climate Change: Federal Actions Will Greatly Affect the Viability of Carbon Capture and Storage As a Key Mitigation Option

GAO-08-1080 September 30, 2008
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Summary

Key scientific assessments have underscored the urgency of reducing emissions of carbon dioxide (CO2) to address climate change. Many have cited carbon capture and storage (CCS) as an essential technology because it has the potential to greatly reduce CO2 emissions from power plants while allowing for projected increases in electricity demand. CCS involves capturing CO2 from a power plant's emissions, transporting it to an underground storage location, and then injecting it into a geologic formation for long-term storage. As requested, GAO examined (1) key economic, legal, regulatory, and technological barriers impeding commercial-scale deployment of CCS technology and (2) actions the Department of Energy (DOE), Environmental Protection Agency (EPA), and other agencies are taking to overcome barriers to commercial-scale deployment of CCS technology. Among other things, GAO examined key studies and contacted officials from pertinent agencies, companies, and environmental groups, as well as research and other organizations.

Nationally-recognized studies and GAO's contacts with a diverse group of industry representatives, nongovernmental organizations, and academic researchers show that key barriers to CCS deployment include (1) underdeveloped and costly CO2 capture technology and (2) regulatory and legal uncertainties over CO2 capture, injection, and storage. Key technological barriers include a lack of experience in capturing significant amounts of CO2 from commercial-scale power plants and the significant cost of retrofitting existing plants that are the single largest source of CO2 emissions in the United States. Regulatory and legal uncertainties include questions about liability concerning CO2 leakage and ownership of CO2 once injected. According to the National Academy of Sciences and other knowledgeable authorities, another barrier is the absence of a national strategy to control CO2 emissions (emissions trading plan, CO2 emissions tax, or other mandatory control of CO2 emissions), without which the electric utility industry has little incentive to capture and store its CO2 emissions. Moreover, according to key agency officials, the absence of a national strategy to control CO2 emissions has also deterred their agencies from resolving other important practical issues, such as how sequestered CO2 will be transported from power plants to appropriate storage locations and how stored CO2 would be treated in a future CO2 emissions trading plan. Federal agencies have begun to address some CCS barriers but have yet to comprehensively address the full range of issues that would require resolution for large-scale CCS deployment: (1) DOE's research strategy has, until recently, devoted relatively few resources to lowering the cost of CO2 capture from existing coal-fired power plants, focusing instead on innovative technologies applicable to new plants. In recent years, however, the agency has begun to place greater emphasis on CCS technologies applicable to existing facilities. (2) EPA issued in July 2008 a proposed rule to guide the permitting of large volume, or commercial-scale, CO2 injections. It addressed at least some of the key issues under the Safe Drinking Water Act but left other issues related to EPA's implementation of its air, hazardous waste and substance statutes unresolved. (3) Other agencies, such as Interior and Transportation, have jurisdiction over a number of interdisciplinary issues that could delay CCS deployment if unaddressed, but which have thus far received little attention. These include, among others, a legal and regulatory regime for a national CO2 pipeline infrastructure and a plan for addressing CO2 emissions reductions from CCS in a future emissions trading plan. In addition, unless the effects of CCS deployment are clearly explained, public opposition could delay future CCS projects.



Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Implemented" or "Not implemented" based on our follow up work.

Director:
Team:
Phone:
John B. Stephenson
Government Accountability Office: Natural Resources and Environment
(202) 512-6225


Recommendations for Executive Action


Recommendation: The Secretary of Energy should direct the Office of Fossil Energy to continue its recent budgetary practice of helping to ensure that greater emphasis is placed on supporting technologies that can reduce greenhouse gas emissions at existing coal-fired power plants.

Agency Affected: Department of Energy

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of EPA should more comprehensively examine barriers to CCS development by identifying key issues that fall outside the agency's Safe Drinking Water Act (SDWA) authority. Specifically, the Administrator should direct the cognizant EPA offices to collectively examine their authorities and responsibilities under Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and the Clean Air Act for the purposes of (1) obtaining the information necessary to make informed decisions about the regulation of (and potential liabilities associated with) the capture, injection, and storage of CO2; (2) using this information to develop a comprehensive regulatory framework for capture, injection, and underground storage of CO2; and (3) identifying any areas where additional statutory authority might be needed to address key regulatory and legal issues related to CO2 capture, injection, and storage.

Agency Affected: Environmental Protection Agency

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Executive Office of the President should establish an interagency task force (or other mechanism as deemed appropriate) to examine the broad range of issues that, if not addressed proactively, could impede large-scale commercial CCS deployment and to develop a strategy for cognizant federal agencies to address these issues. Among the issues this task force should examine are: (1) identifying strategies for addressing regulatory and legal uncertainty that could impede the use of federal lands for the injection, storage, and transport of CO2; (2) examining how any regulation of carbon emissions will address leakage of stored CO2 into the atmosphere; (3) developing an accounting protocol to quantify the CO2 emissions from capture, transport, injection, and storage of CO2 in geologic formations; (4) examining CO2 pipeline infrastructure issues in the context of developing a large-scale national CCS program; (5) developing a public outreach effort to explain CCS; (6) evaluating the efficacy of existing federal financial incentives authorized by the Energy Policy Act of 2005 and other relevant laws in furthering the deployment of CCS; and (7) examining the federal and state resources required to implement the EPA's expanded Underground Injection Control program incorporating commercial-scale CCS.

Agency Affected: Executive Office of the President

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.