ARCTECH Inc. is not an electric utility, nor a mining company, nor an environmental campaigner.
“We believe your consideration of our creative approach of coal use as a [best system of emissions reduction] will offer the industry to comply with your mandates without incurring higher costs, rather increasing economic value,” wrote Walia in his comments. “It will alleviate concerns of many that your mandates will adversely impact the US economy.”
Since the standards were initially proposed by EPA in 2012, the visible debate has been between environmental groups, which have been eager to pass meaningful policies to curb climate change, and coal energy backers, who worry that the standards will wreak havoc on the economy.
In September, the agency reproposed to limit carbon dioxide emissions to 1,000 pounds per megawatt-hour for combined-cycle natural gas facilities and to 1,100 pounds per MWh for coal-fired power plants. It also recommended carbon capture and storage (CCS) as the “best system of emissions reduction” for removing carbon dioxide emissions from coal plants, and either storing the gas underground or using it to squeeze out oil from aging petroleum fields.
Since the proposed rule was published in the Federal Register in January, close to 1 million comments have been filed, according to the rule’s online docket. Many of them make common arguments for or against the rules: that climate change is a serious issue that must be addressed by regulation, that carbon capture and storage (CCS) is an unproven technology that should not be considered the best system of emissions reduction, or that EPA may be overstepping its legal authority in setting different standards for coal and gas.
But the four-month comment period has also garnered submissions from less prominent sources, like technology companies, biotechnology trade groups and farmers.
BIO is the world’s largest biotech organization. Its members develop technology in the health, environmental, agricultural and industrial sectors. BIO Executive Vice President Brent Erickson took the opportunity to ask EPA not to regulate wood-based energy — known as biomass — as coal. EPA is currently deciding how to account for biomass emissions and may begin a separate rulemaking process.
Make room for wood-burning and algae
“Electric Utility Generating Units (EGUs) firing biomass, regardless of percentage, should not be subject to the proposed standards,” wrote Erickson, who heads BIO’s environmental and industrial section, in a press release on the comment submission. In addition, EPA should also incorporate “beneficial reuse” of CO2 that would facilitate the sale of CO2 for industrial purposes, rather than just enhanced oil recovery. Enhanced oil recovery is the process in which CO2 is used to push remaining crude oil from old oil fields.
San Diego-based Sapphire Energy and Florida’s Algenol are two companies that would like EPA to broaden the options for carbon dioxide. Both companies use algae to make fuel. Sapphire makes a “green” crude oil from algae and has secured deals with two oil refineries to process its oil to make bio-based versions of petroleum products. Algenol makes ethanol from algae.
Algae thrive on CO2, and the capture of the gas could provide a ready market for the growing industry, said Tim Zenk, vice president of corporate affairs for Sapphire.
Sapphire recently announced a partnership with oil refiner Phillips 66, in which Phillips will help Sapphire through the regulatory process of registering algae crude as a transportation fuel (ClimateWire, Dec. 10, 2013).
Phillips 66 recently visited EPA to discuss another issue with the New Source Performance Standards, their treatment of combined heat and power plants (see related story).
Although biofuels companies and farmers tend to see eye-to-eye on another regulation overseen by EPA — the federal renewable fuel standard — the Iowa Farm Bureau warned the agency that regulations that encourage electricity generation from cleaner-burning natural gas could lead to price increases in an important material for growers.
“Natural gas is the principal feedstock in the production of nitrogen fertilizer, which is a vital input for farmers to grow crops,” wrote Kevin Kuhle, national policy adviser for the Iowa Farm Bureau Federation. “Should new supply sources be restricted while utility demand for natural gas is increased, we could see increases in the price of natural gas and fertilizer that could raise input costs.”
However, not all rural groups cast the proposal in a negative light. Although the rule has its deficiencies, primarily the lack of functioning, commercial examples of CCS, action to curb climate change takes precedence, said Lauren Kolojejchick-Kotch, the energy and climate organizing fellow at the Lyons, Neb.-based Center for Rural Affairs.
The final rule should include more incentives to generate electricity from wind and solar energy, wroteKolojejchick-Kotch.
“Construction of turbines, solar panels, and associated parts also has the potential to enliven the manufacturing industry in numerous states,” she wrote. “Rather than build new coal plants that require carbon capture technology, many states will have more reason to invest more heavily in renewable as a tool for economic development.”