In an interest to speed up the phase-out of unabated coal power by 2030, the Canadian federal government amended its Coal-Fired Power Generation Regulations. Carbon Capture and Storage (CCS) has a critical role to play in Canada’s coal emissions phase out.

More formally known as the Regulations Amending the Reduction of Carbon Dioxide Emissions from Coal-fired Generation of Electricity Regulations, the "Coal Regulations" were published in the Royal Gazette on February 17th along with the Regulations Limiting Carbon Dioxide Emissions from Natural Gas-fired Generation Electricity (Natural Gas Regulations). The Coal Regulations in partnership with the new Natural Gas Regulations, are a duo of performance standards that will incent a switch to lower emissions from power generation in Canada.

I was in Ottawa recently and was consistently asked about how CCS is impacted by these regulations. I hope this Blog post adds some clarity. The new amendments in the Coal Regulations do not limit the use of CCS - in fact CCS is still explicitly supported. The Canadian government has told us they support CCS, and that during international discussions around “unabated” coal, CCS remains a consideration.

"CCS Excluded
(5) The CO2 emissions from a unit... do not include emissions that (a) are captured in accordance with the laws of Canada or a province that regulate that capture; (b) are transported and stored in accordance with the laws of Canada or a province, or of the United States or one of its states, that regulate that transportation or storage, as the case may be; and (c) are not subsequently released into the atmosphere.” 

-  Taken from the Coal Regulation amendment

The Regulatory Impact

Eleven coal units in the province of Alberta have announced that they will switch to natural gas instead of using CCS on coal, however, the Regulatory Impact Analysis Statement (RIAS) for the Coal Regulations indicates that such conversions have not yet occurred. In Saskatchewan, CCS options on coal are still being explored. The RIAS for the Natural Gas Regulations explicitly says that coal-to-gas conversion in Saskatchewan has not been announced so considered “unlikely”, and “alternatives, such as carbon capture and storage” will play a role.

As indicated in its RIAS, the Coal Regulations expect a 16.3Mt reduction in emissions by 2030 at a $1.9 billon compliance cost, or $116 per tonne (Canadian Dollars). With many provisos, it estimates that from 2019-2055 the cost to build replacement capacity is $466 million; the total cost to decommission units is $54 million; and the additional cost to supply customers with electricity is $1,894 million. The new Coal Regulations are expected to increase imports and reduce electricity exports to the United States to a net value of approximately $1.4 billion.

CCS Exceeds Standards

Without CCS, a lignite coal facility like Boundary Dam would emit 1100 tonnes per gigawatt hour (t/GWh); the federal performance standard for coal-fired power is 420 t/GWh. So – traditional coal fired power is nowhere near the standard and the regulations require its phase out. But, by capturing 90% of emissions, Boundary Dam has the capacity to achieve emission rates of 120-140 t/GWh – which categorizes CCS as a clean technology option which meets performance standards.

Traditional natural gas-fired power facilities emit in excess of 500 t/GWh, with newer combined-cycle facilities operating at 375 t/GWh. This is cleaner than the coal performance standard, but not cleaner than CCS on coal power. In switching to natural gas, the increased fuel costs anticipated are $667 million. In the future, natural gas-fired power plants may also require CCS to reduce their emissions. 

So, what does all this mean? 

We asked that question to expert panelists at last week’s GLOBE conference. John Loughhead, the UK’s Chief Scientific Advisor, explained that it becomes very expensive, and very difficult, to achieve a reliable energy system with the reductions in emissions that you want if you don’t have some means of using fossil fuels; but you still have to prevent the emissions from entering the atmosphere. It was noted that the Powering Past Coal Alliance, supported by the UK, Canada and other countries to promote the principle of banning the use of unabated coal in the near term, is often misnamed in the headlines.  

“CCS is a part of all the scenarios we believe are credible for the future." 

- John Loughhead, UK's Chief Scinetific Advisor

To this Loughhead clarified that the "unabated" aspect is important, because using coal without some attenuation of the carbon dioxide emissions is unsustainable given our desired emission reduction pathways. He said, “CCS is a part of all the scenarios [modelled in the UK] we believe are credible for the future." This is a common message that we have found in various reports from the International Energy Agency and International Panel of Climate Change. Ultimately, CCS is part of the energy transition for coal and other industries – CCS supports the phase out of coal emissions.