Thanks Amity...

http://www.powermag.com/POWERnews/House-Dems-Introduce-Draft-for-Comprehensive-Clean-Energy-Act_1811_p3.html

Found this from a Power Industry source...

"In defining what constitutes a “hazardous air pollutant,” the legislation also tackles a key concern in the landmark Supreme Court case Massachusetts v. EPA (2007), saying that “No greenhouse gas may be added to the list of hazardous air pollutants … unless such greenhouse gas meets the listing criteria … independent of its effects on climate change.”"

Also, the article indicates there are some proposed standards on Coal Fired Power Plants. It cites 1,100 lbs/Mw-Hr if permitted before 2015 and 800 lbs/Mw-Hr if permitted after.

What is interesting is this really dictates CCS from the get-go. An Advanced Super-critical Coal plant will emit about 1,740 lbs/Mw-Hr. with full CCS (90% recovery) it would drop to about 225 lb/Mw-Hr. By comparison, a simple cycle natural gas fired plant emits 1,300 lb/Mw-Hr and a combined cycle natural gas fired plant emits about 750-800 lb/Mw-Hr. Long term most analysts think that by 2025 to 2030 all carbon based electric power will have to be generated with full sequestration or will need to be replaced with non-carbon sources (renewables & nukes) to meet GHG reductions. This is because it will be cheapest to accomplish it on Electricity first. (it would be much cheaper than non-Carbon fueled autos; so you can see a scenario where gasoline purchasers pay the Electric Power generators to fully recover CO2 so they can continue to drive)

And the good news is that the bill addresses a lot of the legal, regulatory and commercial issues that will be associated with CCS... When you start getting into questions like who owns the rights to the sequestration space, what happens if it leaks, etc. it gets real cloudy fast...

I really have a lot of concerns over cap & trade (vs. Carbon Tax); but the issue is so complex, that one car seriously argue that it is the only way to really accomplish the goal without excessively harming economic activity...

I'm pretty sure hydrogen sulfide is already classed as a "pollutant," but no one is trying to fine or arrest active volcanoes.

Your argument fails.

Mike Sulzer wrote:

"Such a simple flawed means of regulating CO2 as a pollutant would indeed be ridiculous, and there is no reason why it would have to be done that way. The producers causing a net increase can be identified if they are of significant size, or belong to a group that can be monitored."

But what is being discussed here is the politics, not the practicality of regulation. Certainly you can single out the dangerous polluters, but their counter argument if CO2 itself is classified as the pollutant, and not the orignation of the CO2, is that others need to share the burden, since CO2 is produced by numerous sources.

Essentially, the choice to not classify CO2 as a pollutant is a political decision. It is based on an understanding that classifiying it as such would lead to a much more difficult road to regulation of dangerous CO2 than simply approaching it from a Carbon source approach.

That was an extremely useful explanation, thanks!

wrote this:

...and when it is produced as part of normal organic resperation, or the combustion of modern materials, there is not net addition of CO2 to the atmosphere, even if there is a release of greenhouse gases.

which is very close to true, but then wrote:

To classify CO2 as a pollutant suggests that regardless of it's source, all CO2 is equal in the eyes of the law. If CO2 is regulated on a parts per million placed into the atmosphere basis, then dairy farmers will be as subject to regulation as Coal fired power plants.

Such a simple flawed means of regulating CO2 as a pollutant would indeed be ridiculous, and there is no reason why it would have to be done that way. The producers causing a net increase can be identified if they are of significant size, or belong to a group that can be monitored.

I think you have to first understand what a Criteria Pollutant is... Historically, CO2 hasn't been one. Carbon Monoxide, Unburned Hydrocarbons, NOx, SO2, Particulate Matter have been, and Mercury will be. This is because they cause direct or nearly direct physical health harm to human beings. CO2 and other GHG do not cause direct harm. Their harm comes from a long term buildup and global warming.

The reason the courts have rejected the Bush admins attempt to use Cap and Trade on things line mercury, and other criteria pollutants, is because it allows for health risks to be left unaddressed in one particular areas by making specific improvements/offsets in other locations. Reducing one pollutant in Corpus Christ doesn't help solve an air issue in Dallas. so the courts have restricted this.

CO2 and other GHG are much different. There will not be a local impact to the pollution. Carbon Dioxide emitted from a Natural Gas Power plant in Wyoming or Florida will not negatively harm anyone in either location. The climate change issues are more global in nature. CO2 emitted in Wyoming, Florida or China will have the exact same impact on Global Warming. So either a Cap and Trade or Carbon Tax would be much more effective economically to reduce pollution than the command and control (via direct emissions standards, like gram NOx/HP-HR)(albeit there could be some benefit) methods used for "conventional" "criteria" pollutants.

I think the reason the Bush Admin started to promulgate regulations was to make them politically unpalatable after being forced to do so by the courts. They were being orders of magnitude more draconian on CO2 than on any other pollutants that have direct, immediate, health risks.

I think it would be a huge mistake to go down the path that we currently use for other pollutants with CO2. This would greatly hamstring the economic decisions and trade offs that have to be made (CCS vs. Solar or Wind; Gas-Electric Hybrids vs. reforestation, etc).

....is what we can expect arriving in our mailboxes each month if these energy policies are rushed into legislation.