The adoption of an emission performance standard for all new coal-fired electricity plants is the best policy tool to achieve accelerated adoption of CCS technologies. This emission performance standard would require, in effect, that new coal capacity be built to meet a CO2 emissions standard achievable with the best available CCS technology.
Lead time of several years would have to be provided to permit utilities to learn from the operational experience of demonstration projects and to give the government time to establish the new regulatory framework that would be needed to govern and monitor the whole system. But time is of the essence.
Given how long power plants last, it is vital that they be built with the right, low-carbon technology. While all new coal-fired power would be subject to these emission performance standards, existing power plants would be subject to a declining cap on emissions under a cap-and-trade system that would create incentives for emission reductions through efficiency measures.
Congress should promptly pass legislation declaring that, going forward, no new coal plants would be grandfathered out of having to meet CCS obligations. Additionally, establishing a national CCS system will require not only large-scale R&D and demonstration projects, but also the development of new rules to govern design and operation of geologic repositories, a process that the EPA has only recently begun to explore. Numerous issues will arise based on the need to ensure that the system is safe, that leaks are avoided, that sequestration sites are properly selected and monitored, and that liability is assigned, in the event that there are problems.
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