As the Environmental Protection Agency (EPA) prepares the first-ever national standards for carbon pollution from new fossil-fuel power plants, the coal industry is embarking, predictably, on its latest disinformation campaign to try to block these desperately needed public health and climate safeguards. New coal plants are dirty, risky, and expensive. No wonder the smart money won’t touch them.

Flacks for the coal lobby have their hair on fire about the rumored content of draft EPA standards that haven’t even been released. They say the standards will kill new coal plants. Haven’t they been paying attention? No one wants to build new coal plants. Except for a handful already underway, no more are planned for the foreseeable future. We don’t know what the EPA draft standards say, but we should all be asking a simple question: Exactly why should the EPA write a standard that is gerrymandered to make room for dirty power plants that the private sector does not want to build?

Let’s look at the facts. Starting about 10 years ago, there were waves of announcements for scores of new coal plants. In all, nearly 200 coal plants were proposed. Now only a handful of these projects are technically alive and they are on life support. A small number of proposed plants have permits, but like many previous plants with such permits, most, if not all, of these proposals will turn out to be vaporware. A permit may get a developer a meeting with project financiers but it will not get their money. The finance community understands new coal plants are simply not economic, given the alternatives that are available.

Other than a few plants under construction, there is virtually no prospect of new conventional coal plants being built in the next quarter century, according to the Energy Information Administration (EIA). EIA reports [PDF] no new conventional coal plants coming online after 2012, and only two gigawatts of coal plants with carbon capture and sequestration coming online around 2017; then nothing more through 2035, the end of the EIA forecast period.    

Are the rumored new EPA CO2 standards responsible for the collapse of the new coal plant boom? No. Market forces have rejected new coal plants. Abundant supplies of natural gas have produced lower prices for that fuel and those low prices seem here to stay. Materials costs have risen substantially, and that makes capital-intensive coal plants a bad bet. Energy efficiency is increasingly recognized as the smartest way to balance power supply and demand and is enabling economic growth with lower electricity demand. Cost reductions in renewable resources like wind and solar, along with supportive policies, have resulted in rapid growth of these cleaner energy sources to meet new demand and replace retiring dirty coal plants.

The market is also penalizing proposals for new conventional coal plants due to their very high CO2 emissions. Financiers know that denying the fact of global warming will not make it go away. So a project with high CO2 emissions has a large built-in financial risk that only grows over time. And that risk is unbounded, since without a clear policy roadmap it is impossible to make a reliable estimate of what it will cost to mitigate a conventional coal plant’s high CO2 emissions. 

The long lead time for coal plants underscores the conclusion that these projects are bad bets. It takes about 10 years to build a coal plant from initial conception to start-up. Then it takes another 15-25 years for investors to get their money back. Even without low gas prices, investors would have to believe that no action to address CO2 pollution will be taken over the next quarter century for them to put their money at risk in new conventional coal plants. This is not a risk that sensible investors are willing to take. So it should be no surprise that plans for new coal plants have been abandoned right and left in the United States.

As for a new EPA standard for CO2, we won’t know what it says until early next year, according to EPA Administrator Lisa Jackson. But let’s assume the EPA were to propose a fuel-neutral standard for new fossil plants, one that could be met by new natural gas combined-cycle plants or by new coal plants with carbon capture and storage (CCS). Such a standard would not prevent the construction of new coal plants (if and when the private sector decides such plants are a better option than alternatives). No, such a standard would just provide a level playing field for the two leading fossil fuels in the power sector: coal and natural gas. (Such a standard would not create a truly level playing field for electric resource investments since it would still heavily favor fossil fuels over zero-emitting options like efficiency, renewables, or nuclear if the latter’s many problems could be solved.) 

Such a fuel-neutral CO2 standard would permit a new coal plant designed to capture about 60 percent of its CO2 to be built. The coal lobby will complain about the cost of CCS, but that cost will never get lower if standards are rigged to ensure no new coal plants will ever have to employ CCS. Why spend money to improve a technology for which there is no market? 

The bottom line is that it is not the cost of CCS that is blocking new coal plants today; it is the cost and risks of plain old dirty coal plants compared to the alternatives that are shelving these proposals.

Of course, no one should be surprised that the coal lobby thinks that a level playing field standard is the policy equivalent of the swine flu. But should we build new power plants in order to prop up the coal industry? We want new power resources, not to help burn more coal, but to provide heat, light, comfort, and convenience, and to do so reliably and in a manner that does not send our kids to the emergency room with asthma attacks, our parents to an early death, or condemn our grandchildren to a planet with a climate so disrupted that their lives will be an unending torment.

Despite the coal lobby’s rhetoric, building new conventional coal plants is a bad economic bet for society as well as for individual investors. Even in countries where building a new coal plant appears to be cheaper than investing in cleaner energy, the International Energy Agency (IEA) reports that going down such a path will produce huge net economic losses. IEA reports [PDF] that for every dollar “saved” by investing in a dirtier power plant before 2020, countries will wind up spending more than $4 after 2020 to overcome the impact of those dirty investments.

So let’s have the debate. The market has walked away from conventional coal plants. Should the EPA try to hold back the tide of market forces? Should the EPA set CO2 standards for new power plants that are twisted to make the coal industry happy? Or should the EPA follow the law and good policy and set standards that provide a level playing field for coal and natural gas and avoid locking us into another round of new multi-billion dollar old coal technology that will cost us more and damage our health and the only climate we have?

Cross-posted from the Natural Resources Defense Council.

It’s a sad state of affairs when members on both sides of the aisle in Congress seem to think it is a good idea to attack the Clean Air Act — the landmark law that Richard Nixon signed and George H. W. Bush strengthened. Yet the hits on the Clean Air Act just keep on coming in this Congress in spite of the act’s incredible record of cutting deaths and illness caused by air pollution — a record that has earned the strong support of the American people and the admiration of others around the world.

Clean Air Act phobia appears to be a strangely contagious disease that keeps showing up in members’ pronouncements and draft bills — a disease impervious to information and common sense. Among the current symptoms of this disease are the attacks on the act’s provisions that would require some of the world’s largest pollution sources to apply sensible methods to cut the amount of global warming pollution they dump into our atmosphere — the one atmosphere Earth has — every year. 

Over the past month or so, I and my colleagues have alerted readers to the latest attacks on the act (here, here, here, and here, to provide just a few examples). The new attacks this week have been happening in the Senate: starting with Sen. Mitch McConnell’s (R-Ky.) amendment to add a poison pill to an unrelated small business bill and joined by Sen. Jay Rockefeller (D-W.Va.) with his own version the next day.

The latest development comes from Sen. Max Baucus (D-Mont.). The trade press reports [sub req] that the purpose of his amendment is to codify EPA’s rule that exempts small pollution sources from certain Clean Air Act permitting rules. If the Baucus amendment did only that, there is a good case that congressional action would make sense. But, whether intended by Sen. Baucus or not, his amendment contains two very damaging provisions that go far beyond codifying the tailoring rule.

First, the amendment would permanently prohibit EPA from looking at global warming emissions due to changes in land use (like cutting down a mature forest or releasing huge amounts of carbon from soils) when calculating how much global warming pollution would result from a new industrial project. The scientific literature demonstrates that if not produced correctly, biomass energy can increase global warming pollution, not reduce it. In essence, this provision in the Baucus amendment would require EPA to lie to the public about the true global warming impacts of projects like a new power plant that burns trees for fuel. 

Putting blinders like this on EPA would create large perverse incentives to pursue damaging projects, knowing that the cop had been ordered to look the other way. The provision would interfere with good biomass projects by preventing EPA from giving those projects credit for increasing the amount of carbon in soils and vegetation. Finally, the provision could prevent implementation of Congress’ renewable fuels standard by preventing accurate calculation of the emissions performance of biofuels. EPA has embarked on a lengthy process to develop scientifically robust methods of calculating emissions from biomass energy production and use. Gathering facts from interested parties and experts in an open, transparent process is the right way to address this issue.

Second, the Baucus amendment contains a provision that would permanently exempt even the very largest global warming pollution sources from the act’s new source permitting requirements unless the source was also a very large source of other pollutants. While it makes sense to limit the new source program to large pollution sources, it would be a serious mistake to ignore the largest sources of global warming pollution just because they did a good job controlling other pollutants. Other provisions in the Baucus amendment assure that only very large sources of global warming pollution would be reviewed so this additional provision is unnecessary and harmful.

So I ask those in Congress who think that blocking the Clean Air Act’s global warming pollution programs is reasonable, to consider this. The damage from such bills would be inflicted on the truly unrepresented — Americans and other people around the world. Letting polluters put their global warming wastes in the air today will harm our children and their children and their children’s children. Global warming pollution just doesn’t go away fast — half the carbon pollution we put in the air when our great-grandfathers fought World War I is still in the air today. And 1,000 years from now, 15 percent of the pollution from those years will still be in the air. So congressional attempts to block EPA from carrying out the Clean Air Act provisions to reduce carbon pollution are no minor missteps, easily remedied by a future Congress. No, these are actions that would condemn generations to the additional damage caused by pollution that can and must be avoided. 

Rep. Upton wrote the bill with his trunk.Photo: Eric Molina

Barry Goldwater famously said, “extremism in the defense of liberty is no vice.” Maybe so, but extremism in the defense of fantasy is a tougher sell. Still, that doesn’t stop some members of Congress from trying.

Exhibit A this week is the attempt to legislate an alternate reality, offered up by Reps. Fred Upton (R-Mich.) and Ed Whitfield (R-Ky.) with accompanying cheers from Sen. Jim Inhofe (R-Okla.). Their draft bill would eliminate Clean Air Act provisions that would allow the EPA to set common-sense standards to cut the pollution from large industrial polluters that causes climate disruption. Whitfield chaired a hearing on this bill [PDF] today. (You can find my full statement on this bill here [PDF].) The authors call their bill the “Energy Tax Prevention Act of 2011″ but a better name would be the “Reality Prevention Act.”

The novel idea in this bill is that Congress can simply vote out of existence scientific facts that a majority does not like. That’s what this bill would do. It would “repeal” (yes, the bill really says “repeal”) a scientific determination by the EPA that carbon dioxide and other greenhouse-gas pollutants are a threat to human health and welfare. Interesting concept: EPA scientists, after studying the work of thousands of other scientists, conclude that global warming pollution threatens our health and welfare. And Congress responds, “No it doesn’t and we have the votes to prove it!”

Why didn’t we think of this before? All those threats in the real world that concern us? Let’s just vote them away. Let’s vote that cigarettes do not contribute to lung cancer; let’s vote that lead and mercury are not brain poisons; let’s vote that diet and lack of exercise have nothing to do with being overweight. Let’s vote there is no flu virus on the way (we can save all that spending on vaccines). Let’s vote that the threat of terrorist attacks on America is over (hooray, no more airport pat-downs).

Gosh, voting away the science we don’t like is so much easier than actually thinking about these problems and deciding what to do about them.

“Ahh,” you may think, “wasn’t that EPA report just an Obama administration invention?” But you would be wrong. EPA’s study was actually the result of a Bush administration program, started in 2001, to study the science of climate change. Jump to 2007, when the Supreme Court told EPA to decide whether greenhouse-gas pollution is a threat to public health and welfare and if it is, to do something about it using the tools in the Clean Air Act. So in May 2007, President George W. Bush directed the EPA to respond. After nearly three years of work, including two rounds of public comment on draft reports, the EPA concluded in December 2009 that the science does indeed demonstrate that carbon dioxide and other greenhouse-gas pollution endanger public health and welfare. Following additional challenges to this final report, the EPA published yet another voluminous report that responded to all those critiques. And all of these findings are now being reviewed by the courts.

But, maybe Upton and Whitfield commissioned their own independent expert scientific review that shows the EPA’s conclusions were flawed? Well, noooo … actually there is no contradictory independent report. The reality is that the EPA’s conclusions are completely consistent with reports of other scientific studies in the U.S. and around the world [PDF]. But if you can create your own reality by voting it into being why waste all that time considering the facts?

Which brings me to the second novel aspect of this bill. As well as inventing their own science, the authors have invented their own version of the existing Clean Air Act rather than the real one that Congress enacted. You see, in addition to repealing the EPA’s science decision, the bill also overturns the Supreme Court’s ruling that carbon dioxide is a pollutant under the Clean Air Act and it repeals all of the EPA’s authority to limit this pollution (or to think about it any manner) in order to protect against climate disruption. The authors argue these extreme measures are needed because the current Clean Air Act gives the EPA enormous power to do deep harm to the American economy. That’s where the authors’ second alternate reality comes in. In the real world, the existing Clean Air Act does not allow the EPA to set rules that would create economic disruption.

There are three provisions of the Clean Air Act that the EPA could use to cut carbon dioxide pollution and each one of them explicitly requires the EPA to prove that any pollution standards it sets are technically feasible and economically reasonable. For example, last year the EPA, working with automakers, set tailpipe standards for new vehicles. The act allows the EPA to set those standards only if the EPA demonstrates there is available technology to meet the standards, considering the “cost, energy, and safety factors” associated with using the technology. (CAA, Sec. 202 for you budding lawyers)

Next, the EPA has issued rules requiring large new pollution sources (as well as existing sources that are modified so pollution increases) to apply options that are technically feasible and affordable to reduce greenhouse-gas pollution. This requirement has been in operation for other pollutants for over 30 years under a provision that, you guessed it, requires the EPA or state agencies to determine, on a case-by-case basis, that any standard they set must be “achievable,” “taking into account energy, environmental, and economic impacts and other costs.” (CAA, Sec. 169)

Finally, the EPA plans to adopt emission standards for coal, oil, and gas power plants and for oil refineries (and maybe other large industrial sources in the future). As with the EPA’s other authorities, the Clean Air Act limits what the EPA is allowed to do: Any emission standards it adopts under this part of the law must not only be technically achievable but the technology must be “adequately demonstrated, taking into consideration the cost of achieving such emission reduction, any nonair quality health and environmental impact and energy requirements.” (Sec. 111) (Yep, some inventive scribe actually stuck “nonair” into the Clean Air Act. Hey, English is a living language, right?)

So, while the imaginary Clean Air Act of the Upton-Whitfield-Inhofe world would allow the EPA to run amok, the real Clean Air Act already does what they claim they want to do, which is to make sure that the EPA is not able hurt the U.S. economy as it requires polluters to clean up their act.

But maybe the Clean Air Act is like the old Soviet Constitution — looks good on paper but in the real world it sucks. Noooo … here too the real world puts the scare claims to rest. A peer-reviewed study comparing all the compliance costs imposed by Clean Air Act rules from 1970-1990, to the economic benefits produced by these rules in that period, concluded that benefits amounted to $22 trillion, while compliance costs were $525 billion — a 40-to-1 payoff ratio for the American economy. A later study for the period from 1990-2020 finds that updated Clean Air Act pollution-cutting standards will continue to deliver benefits far in excess of compliance costs.

All this would just be the stuff of dark humor if the stakes for real human beings were not so high. Climate disruption is a problem that can sneak up on you, especially if you hold beliefs that make you want to look the other way. Our best hope is that there are people of good judgment who can reach the politicians who believe that the threat is not real or that we can afford to wait even longer before acting. The basis for the Upton-Whitfield-Inhofe bill is fantasy, but it would do huge damage in the real world if it ever became law.

Michael G. Morris
Chairman of the Board
President and Chief Executive Officer
American Electric Power
September 17, 2010

Dear Mike,

I am writing about your letter of September 15, 2010, urging the Senate to enact legislation that would prevent EPA from issuing rules under the Clean Air Act to limit greenhouse gases for at least two years. While you sent this letter in your role as Chair of a Business Roundtable task force, I know you well enough to believe that you personally agree with the statements in the letter. With that in mind I want to provide you with my reasons for strongly disagreeing with those claims.

You start by arguing that the Clean Air Act is not well-designed to regulate “ubiquitous pollutants like carbon dioxide emissions, whose impact is global, not local or regional.” That argument might apply to the Act’s ambient standards programs but EPA has made it clear that it has no intention of applying those provisions of the law to greenhouse gases. Rather, the agency has stated that it will use the law’s technology-based provisions to achieve reductions in these pollutants. These provisions are as well-suited to greenhouse gas pollutants as they are to the range of traditional pollutants for which EPA has developed emission performance standards over the past 40 years.

The core boundary on EPA’s authority for emission performance standards, including “best available control technology” (BACT) and New Source Performance Standards (NSPS), is that the standards must be supported by a thorough record documenting the technical and economic reasonableness of any standard the agency adopts. These findings of reasonableness are required to be made on a category by category basis, and in the case of BACT, on a source by source basis.

EPA’s use of these provisions will implement an entirely sensible policy to apply modern techniques to reduce emissions from major new investments in our nation’s industrial infrastructure, in a manner that is compatible with sustainable economic growth. The claim that implementing these common sense provisions would drive up consumer costs and damage U.S. competitiveness is simply without any factual basis. To the contrary, a path that would encourage investments that will lock our economy into a high carbon pathway is the real threat to consumer well-being and competitiveness.

As CEO of American Electric Power you have recognized that action by the U.S. to cut its emissions is a necessary step to engage other countries in similar efforts. Congressional backtracking on the Clean Air Act — a law it has already enacted and that the Supreme Court has concluded applies to greenhouse gases — would set back efforts by the U.S. to demonstrate the leadership that is essential to securing the cooperation of other countries in addressing this global threat. I know that you and other Business Roundtable leaders understand that ill-considered actions by the U.S. can damage progress toward our international objectives.

The current Administration has tried to break the international log-jam on climate protection by stating the commitment of the U.S. to reduce its emissions by reasonable amounts by 2020. Timely exercise of the Clean Air Act performance standard authorities can contribute to that effort even if the Congress delays in enacting the more comprehensive legislation that you and I agree is needed. Action by EPA would properly be seen as good faith progress by the U.S. and would enhance our ability to secure more action from other countries. In contrast, enactment of the legislation you seek would send a signal that the U.S. cannot be counted on as a reliable partner in a global effort to tackle this problem.

Your letter emphasizes that the delay you seek is for two years and that it would allow time to formulate approaches that to develop needed new technologies. I have several disagreements with this argument. First, investments are being made now and there are a range of available resource choices with quite different greenhouse emissions profiles. Blocking EPA action for the extended time contemplated in this legislation will skew decisions away from alternate, available resources with lower carbon emissions.

Second, the legislation you support is not limited to delaying the effectiveness of EPA rules for two years. Rather, it is drafted to prevent EPA from taking any action related to rule development during the proposed two year period. So, in practice, the delay imposed by such a provision would last years longer. Third, such a provision, once enacted, will be a convenient predicate for extending the delay with successive enactments of the same provision. This technique was used to bar action to improve fuel economy standards year after year during the 1990s. Indeed, before the legislation you support has even been voted on, influential members of Congress are making public statements about renewing it. Nothing in the legislation itself nor in the dynamics prevailing in Congress creates meaningful incentives to use the time period when EPA is blocked to develop alternative legislative approaches.

In reality, the most likely result of enactment of such a delay would not be to stimulate increased efforts to develop a legislative consensus on climate protection. Rather, hamstringing EPA would empower those who have succeeded in preventing action by Congress on broad climate legislation for years now. That will serve neither the interests of climate protection nor the interests of the many Business Roundtable members who face genuine problems in making rational business plans as long as U.S. climate policy remains in an unresolved, contentious state. Enactment of a provision like the Rockefeller proposal would assure an increase in controversy surrounding U.S. energy policy and every major emitting energy project. That turn of events would make it harder, not easier, to find common ground on how to move forward.

Mike, I know you have worked hard to move AEP from a stance of opposition to public health and environmental progress to a forward-looking posture that emphasizes cooperation. Those efforts have already produced dividends that benefit AEP and the public generally. This effort to handcuff EPA from taking any action, no matter how moderate, on greenhouse gases is unnecessary and inconsistent with the approach you have taken up to now. Rather than urging a meat-ax approach by Congress to block EPA from carrying out the law, why don’t you join us in working with EPA to develop common-sense performance standards that will reduce uncertainty while moving us in the right direction on climate protection?

With best wishes,

David G. Hawkins
Director, Climate Programs
NRDC

I attended the celebration of the 40th anniversary of the Clean Air Act at EPA this past week.

It was a breath of fresh air (sorry) to hear so many speakers from industry as well as health groups and from across political divides to give concrete examples of how much good this landmark law has delivered for Americans.  I arrived in Washington as a newly minted lawyer in 1970 and I have personally seen this progress happen.

In 1970 air pollution was recognized as a blight and a serious public health problem but aside from a handful of municipal ordinances and even fewer state programs, it was largely ignored.

The national pollution load was heavy.

In 1970, US sulfur oxides pollution was over 31 million tons per year.  Now it is less than 11.5 million tons.

US hydrocarbon pollution was over 34 million tons per year.  More than half of that from cars and trucks.  Now it is less than 16 million tons.

Nitrogen oxides pollution was nearly 28 million tons per year.  Now it is about 16 million tons.

Carbon monoxide pollution was over 200 million tons per year; nearly all from cars and trucks.  Now it is less than 78 million tons.

These large cuts in pollution are all the more significant considering the fact that our economy grew so much from 1970 until now.

In 1970, US GDP was $3.8 trillion (2000 $).  It is now $13.2 trillion, a 3.5 fold increase.

In 1970 there were 108 million vehicles on the road, driving about 1.2 trillion miles a year.  In 2008 there were nearly 250 million vehicles on the road, driving 3 trillion miles a year.

In 1970, tailpipe controls were in their infancy.  So much so that one car company met the government limit on pollutant concentration by adding an air pump to dilute its exhaust.

Back then, dilution as the solution to pollution was the preferred approach for SO2 at coal-fired power plants too.  It took more than a decade to outlaw the practice of allowing power companies to build tall stacks instead of actually reducing emissions.  Now SO2 scrubbers are in place at over half the nation’s coal plants. And if EPA is allowed to do its job, the remaining unscrubbed coal plants will either get controlled or shut down in the next handful of years.

In 1970 there were no controls on lead in gasoline.  Thanks to the CAA lead is now banned here and countries around the world have followed our example

In 1970, the basic rule for preventing smog-forming hydrocarbon leaks from refineries was a requirement to paint storage tanks white, or floating roof tanks in some places.  Today, that pollution from the chemical and refining industries has been cut in half.

There is no mystery about how this came about.  Plain and simple, the Clean Air Act made it happen.  The combination of programs for ambient air quality standards and emission performance standards made this cleanup occur.  These two tools, complemented by the annual cap on SO2 emissions from the 1990 Act have proven their effectiveness.  They work.  They have made the air cleaner and have done it without hurting economic growth.

Without the Clean Air Act, EPA has recently estimated that today –

• 60 metro areas in the U.S. would have had higher total suspended particulate concentrations than Moscow
• 7 metropolitan areas would be worse than Bangkok
• 6 metropolitan areas would be worse than Bombay.

But the job is not finished.  Pollution from power generation still shortens the lives of an estimated 13000 people per year and sickens many more.  Many of our major cities still have air quality that is unhealthy.  And of course, we have done nothing to address what might be called the mother of all pollutants, carbon dioxide.

As we see renewed claims from polluters that new EPA rules for the largest remaining pollution problems will cost jobs and raise energy prices, it is important to remember they said the same things about every rule EPA adopted in the past 40 years.  They were wrong every time.  Fortunately for all of us, past cleanup efforts went forward despite these claims.  Let’s highlight these facts as we work to bolster EPA and state efforts today and secure continued support from Congress for this remarkable law.

Our community uses several tactics to block new polluting coal plants. We intervene in permit proceedings and bring lawsuits to challenge coal plant permits. NRDC has actively used this tactic, joining the outstanding efforts by the Sierra Club and others. Another tactic, that NRDC also has pursued, is advocacy with Wall Street investors to convince them that investments in new polluting coal plants are a bad bet. A third is advocacy for performance standards that would make it legally impossible for new polluting coal plants to be built. NRDC worked hard to get such a law enacted in California and is seeking such standards in federal legislation. A fourth is to create a broad consensus that no new coal plant should be built unless it captures its carbon.

This last approach, which NRDC has pursued as well, is controversial in our community because it does not call for an absolute bar on new coal plants regardless of environmental performance and it lends legitimacy to carbon capture and storage (CCS) technology. I certainly understand the controversy — after all, if the coal industry seems to be supporting CCS, there is good reason to suspect something nefarious. And Mike Brune is right that the coal industry has a perfect record in speaking with a forked tongue on CCS — claiming that it is an essential technology, arguing that it is not ready, and then working to block any policy that would require it to be used. But the coal industry’s duplicity should not keep us from assessing for ourselves whether CCS can help us stave off climate destruction and increase our use of cleaner energy.

As a community, we have achieved great success in blocking new coal plants one by one but we need a comprehensive coal policy as well. Showing CCS is an available tool helps us to convince policymakers that they should oppose construction of coal plants that do not capture their carbon. Is such a policy as attractive to many in our community as a law that says no more coal plants, period? No. But we need to ask ourselves — what are the realistic odds of getting Congress or any significant coal-using state to adopt a “no new coal, period” policy in the next handful of years? I have fought the coal industry for 40 years and in my judgment the odds of a total ban on new coal plants are not large.

But we do have in our grasp the adoption of policies that will bar the construction of new coal plants unless the plant operates CCS. Securing the votes to get these policies enacted will require convincing some members of Congress that coal plants with CCS could in fact be built. I know that this is objectionable to many in our community but which is a better outcome: leaving the door open to building new coal plants with no CO2 controls at all or leaving it open only to coal plants with CCS?

Right now, the coal industry uses the claim that CCS is not ready as a weapon to fight mandatory CO2 requirements. Those of us who talk to members of Congress know that these claims are influential in far too many offices. The Obama CCS task force is a way to take that argument away from the coal industry.

Some in our community seem to fear that if we admit that CCS might become a tool in the climate protection toolbox that we will lose the battles to deploy truly clean resources like efficiency and renewables and to end atrocities like mountain-top removal (MTR). With respect, I think that view is a mistake. What CCS will do, in addition to cutting carbon pollution, is to internalize one cost of coal use that is currently ignored. That is a huge step forward in ending the distorted market that has allowed coal to dominate electricity production until now. A policy requiring new coal plants to use CCS dramatically improves the economic competitiveness of cleaner alternatives overnight. It is true that CCS will not stop MTR; neither will SO2 scrubbers, NOx controls, mercury controls, or baghouses. But that has never caused us to oppose those vital life-saving control measures in the past. To fight MTR we need to take it on directly, as many are doing brilliantly. NRDC is proud of its work to end this scourge and we won’t stop until MTR is history. As NRDC’s President Frances Beinecke makes clear in her recent blog, supporting CCS does not mean condoning the damages that coal, as it is mined and used today, inflicts on us all.

CCS may also be an additional tool to cut carbon emissions from existing plants. We all want to use efficiency and renewables (and, more controversially, natural gas) to back out coal and carbon pollution from the more than 300GW of existing coal plants. But that won’t happen without strong policies. The reality is that we have not yet made the sale with critical members of Congress that a coal-free energy system is feasible in the near term. However, we can make the sale that CCS can become a real option, with a serious effort and supporting policies. Our community should not be afraid of having an additional tool to go after emissions from existing coal plants. If CCS is shown to be feasible for existing coal plants it will become harder and harder for those plants to justify operating without it. That helps level the playing field for alternatives to coal.

Nor is CCS just about coal. CCS may also turn out to be something we need to get more rapid reductions in greenhouse gas pollution. We all know we should have started a serious climate protection program decades ago. Instead, our “leaders” have let carbon pollution build up at an accelerating rate with a lot more in the pipeline. Most of us fear that we are in for some disastrous impacts just due to what is already in the atmosphere along with the added amounts we cannot prevent in the next few decades. We may well need to pull CO2 out of the air by applying CCS to sustainably produced biomass. Using the politics of coal to prove out CCS so it is available for broader applications may be seen in a decade or so as a smart move.

The energy penalty projected for first-generation CCS systems is a legitimate concern. But we need not worry about a future of massive deployment of high energy penalty CCS systems. If CCS designs do not achieve substantially better efficiencies than the first versions, other low-carbon options will win in the marketplace.

What about the risk that CCS subsidies will enable coal to crowd out superior energy choices? Well, the key feature of the CCS subsidy provisions in the House and Senate climate bills is that payment is tied to actual capture and disposal of CO2. This is a huge change from past subsidies, including those in the stimulus bill, where the payment is not tied to actual tons of pollution avoided. While our community still may not like these CCS subsidies, keep in mind that they are part of a package that will put in place a steadily tightening cap on carbon pollution and a CO2 performance standard for new coal plants. That is a radically different policy environment than the status quo — one that will dramatically increase the prospects for efficiency and renewables. So whether you think, as NRDC does, that pay-for-performance CCS subsidies are an appropriate hedging strategy or that it’s just the price to pay to get the US off the dime on cutting carbon pollution, the odds are that CCS can play a positive role in helping us achieve our goals of moving the U.S. and the world to a cleaner energy future.