Competitive Positioning – Pending New EPA Standards

There is ample information on various DOE websites defining cost and performance baselines for the various types of power plant options currently in today’s available mix. I used DOE/NETL- Baseline 341/082312, August 2012, and DOE/NETL- Baseline 2010/1397, November 2010.

The competitive scenario is totally dictated by the 1000 lb-CO2/MWh emissions standard promulgated in the EPA New Source Performance Standard (NSPS), first released in 2014. Under that requirement a new Supercritical Pulverized Coal plant (SCPC) with Carbon Capture (CCS), Case 12, is competing against a Natural Gas Combined Cycle (NGCC) plant without CCS, Case 13.

I use the term “competition” loosely, because given this threshold level; it is hardly a fair fight. How un-level is it?

Grossly unlevel.

Look at Cases 12, the SCPC w/CCS and compare it to Case 13, the NGCC w/out CCS.

  • The SCPC w/CCS plant is 5X the first cost
  • And, the efficiency of an SCPC w/CCS is ½ at 28.4% vs. 50.2%
  • The Levelized Cost of Electricity (LCOE) for the NGCC without/CCS is ½ that of the SCPC w/CCS and this is based on $6.13/mmBtu cost for natural gas.
  • If the current price for natural gas is considered, the LCOE is 1/3 that of the SCPC

And, you wonder why gas turbines have had record levels of sales??

There are some who would have you believe that this is purely the result of low gas prices, and that this is “just the market place exerting itself”. This is hardly the case. Yes, the price of gas is a factor, but the real driver is that CCS is required in Case 12, but not for Case 13. Yes, the price of natural gas is a huge accelerant, but still that of an accelerant.

The Coal Industry has been spending its political capital trying to make the NSPS threshold simply go away, in which case the competitive comparison would be Case 11 vs. Case 13. In such a comparison, the first cost for the SCPC is 3X and the efficiency at 39.3% vs. 50.2%.

The Coal Industry might want to consider a strategy to push full CCS, which would then position their Case 12 against the NGCC Case 14. The first cost difference would be 2.5X and the efficiency would be 28.4% for the SCPC w/CCS vs. 42.8% for the NGCC w/CCS. Not pretty, but they could actually have the environmentalist community on their side.

The recently announced Clean Power Plan pretends to be agnostic on how each of the states reach their assigned targets, but behind the targets themselves is the built-in assumption that NGCC’s without will provide a ~70% contribution, which would then be driven by the same 1000 lb-CO2/MWh threshold.

The unanswered question in all of this is whether or not this 1000 lb-CO2/MWh threshold, either explicit or implied, reaches the presumed target of 2°C/450ppm. It should be noted that neither the NSPS nor the CPP mention a target, let alone a target of 2°C/450ppm.

It is hard to reach a target if you don’t have one, but on second thought it is actually easier to reach a target if you don’t have one!

Current Competitive Positioning – Rev4.pdf

Peter Baldwin Avatar