Climate Change:

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

GAO-08-1080: Published: Sep 30, 2008. Publicly Released: Sep 30, 2008.

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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 for Executive Action

  1. Status: Closed - Implemented

    Comments: Funding for DOE's "Innovations for Existing Plants" program has increased each year and additional increases were requested for FY 2011, as shown by the following data from DOE's 2011 Budget Request: Detailed Justification (dollars in thousands). The funding for 'Innovations for Existing Plants' in FY 2009, FY 2010, and FY 2011 was $48,600, $52,000, and $65,000, respectively. The IEP activity is focused on the development of post-combustion CO2 capture technology for new and existing plants. Post-combustion CO2 capture technology is applicable to pulverized coal (PC) coal power plants, which is the current standard industry technology for coal-fueled electricity generation." In addition, DOE's Clean Coal Power Initiative has also announced significant projects that are retrofits of existing plants.

    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

  2. Status: Closed - Implemented

    Comments: Per EPA, the following actions were taken by its major media offices and an interagency CCS task force the agency chairs with DOE:Office of Water: published final GS rule under SDWA for Class VI wells in December 2010, and has trained Regional and State permit writers on the rule, and completed a final Financial Responsibility guidance in early 2011. OW will complete 12 additional technical guidance documents to assist implementation of the Class VI program, and is also working with States who wish to receive approval for GS Class VI primacy by September 2011. After that date, EPA will implement Class VI program and permit GS wells in those states without primacy.Office of Air and Radiation: In December 2010, EPA published a final rule that requires facilities that conduct geologic sequestration of carbon dioxide (CO2) and all other facilities that inject CO2 underground to report greenhouse gas (GHG) data to EPA annually. This rule amends the regulatory framework for the GHG Reporting Program. This Program requires reporting of GHG emissions and other relevant information from certain source categories in the United States, including suppliers of CO2. Subpart RR of this rule requires GHG reporting from facilities that inject carbon dioxide (CO2) underground for geologic sequestration, and subpart UU requires GHG reporting from all other facilities that inject CO2 underground for any reason, including enhanced oil and gas recovery.Office of Solid Waste and Emergency Response: will publish a proposed rule (Summer 2011) for excluding CO2 captured from an emission source and injected via Class VI GS wells from regulation under RCRA and seek public comment and publish a final rule before year end 2011.CCS Task Force: In February 2010, the President established an interagency CCS Task Force, co-chaired by EPA and DOE. In August 2010, the Task Force delivered a series of recommendations to the President on overcoming the barriers to the widespread, cost-effective deployment of CCS within ten years, with a goal of bringing five to ten commercial demonstration projects online by 2016. EPA has been working with its Federal partners to implement the recommendations of the Task Force, including regulatory development and continuing efforts to analyze long-term liability and stewardship frameworks. EPA (OW) continues to interact with DOI (BOEMRE) on offshore GS pertaining to its regulation under the MPRSA and OCSLA for subseabed sequestration, and with BLM for GS on federal public lands.

    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

  3. Status: Closed - Implemented

    Comments: On February 3, 2010, the recommended task force was mandated in a Presidential Memorandum calling for a ". . . comprehensive and coordinated Federal strategy to speed the commercial development and deployment of clean coal technologies" through an Interagency Task Force on Carbon Capture and Storage, to be co-chaired by the Department of Energy and the Environmental Protection Agency. The Memorandum specifically calls on the Task Force to "develop a proposed plan to overcome the barriers to the widespread, cost-effective deployment of CCS within 10 years."

    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


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