Aside from the fact that “less climate ambition delivers more” global warming, more sea level rise, more ocean acidification, more unpredictable climate, more migration and more unstable global governance, the arguments portrayed by Euracoal in the report are obsolete, misleading and largely down right incorrect.

The report states that “The coal industry asks that any target for 2030 must be realistic and only decided after the 2015 climate summit in Paris”. As the authors are surely aware, should the EU attend the 2015 UN climate negotiation without any settled ambition level, it would be most unhelpful in terms of getting commitments from other parts of the world.

Flimsy attempt to justify role of coal  

Euracoal further claims that “As a partner for intermittent renewables, coal-fired and gas-fired power plants are equally flexible, but coal can do the job more cheaply and more securely”. Firstly existing European coal power plants are not as flexible as gas fired plants, especially when running from a cold start. [1] Even newer, technically more flexible, coal facilities offer only marginally improved performance. This is due to inherent wear and tear experienced in cycling coal plants. Coal facilities also offer reduced flexibility for commercial reasons, as a result of higher capital cost requiring increased utilisation for NPV positive investments to be made. [2]   Not to mention the increased CO₂ emissions resulting from unabated coal use.

Euracoal does correctly indicate the supply security advantages of indigenous European coal. However, Euracoal does not mention that the European Commission’s communication “European Energy Security Strategy” clearly states “coal and lignite’s CO₂-emissions mean that they only have a long-term future in the EU if using Carbon Capture and Storage (CCS)”. [3] Evidently Euracoal are unaware that CCS does not need coal, but coal certainly needs CCS if it is to have any role in the EU’s future energy mix. [4]

Mixing truths and misconceptions

In phrasing “In the long term, fuel switching to gas is no answer to the climate challenge” the authors have decided to omit the almost universally held opinion that in the short-term, getting rid of unabated coal is a prerequisite to moving towards a decarbonised world. The report follows this quickly by further mixing truths and misconceptions with no source for the relevant information. “The 80-95% cut in GHG emissions by 2050 would require CCS at even gas-fired power plants where it is a more expensive option than for coal plants.” It is evident that a deep decarbonisation of the electricity supply industry will require CCS to be applied to all major point sources including coal and gas plants. However, the blanket statement that CCS on coal is more cost competitive then CCS on gas is simply false.  Many factors influence the commercial viability of all energy sources, including the dispatch role the plant is providing to electricity supply network. In addition natural gas CCS has certain advantages over coal CCS, including lower capital costs along with lower volumes of CO2 to captured transported and stored. [5]

The authors entirely ignore the role of climate policies in reducing damaging CO₂ emissions when they say “Only those with a vested interest call for high carbon prices in the EU, notably the nuclear and renewables sectors and even the gas sector.” The omission of the views of the general public, the scientific community, the environmental NGOs and the majority of MEPs provides a window into the claustrophobic world view Euracoal has managed to construct.

Speaks for ‘realists’ with no reference to real facts

The report talks time and again about “realistic targets for the EU ETS cap”. No indication of what a realistic level may be – but likely the authors are referring to a level that has no negative impacts on coal power plant investments or operation.  Amazingly the authors claim that most industrialists would prefer a “low or zero” carbon price “as long as the EU ETS is an isolated scheme in the global context”, with again no sources give to back up such claims.

The authors brandish simple, sometimes childlike statements such as “The significant effort required by European industry under the Commission’s proposal would reduce global emissions by just 0.25%.” Not grasping that CO₂ reductions must be placed brick on brick shows a basic lack of critical thinking. Furthermore, there seems to be no acknowledgement that emission reduction efforts are taking place elsewhere in the world. In the United States and Canada, with the introduction of Emission Performance Standards (EPS), new unabated coal generation is essentially outlawed. [6]

The report does mention the EU CO₂ storage Directive’s requirement that all new fossil power plants in Europe must be constructed as ‘carbon capture ready’. “Planning for a low-emission future means that new coal- and gas-fired power plants must be built with enough space for CO2 capture to be retrofitted and a potential route to CO2 storage identified”. Unfortunately CCS readiness as it stands is often ignored or under-enforced by both companies and Member States. [7] It is clear that CCS readiness in any form is not necessarily a driver (or even a true facilitator) for CCS deployment, a topic on which the report is otherwise mute.

Report distances coal industry further from CCS

Critically the report does not discuss the role of fossil fuel producers have in enabling the deployment of CCS technologies. This is disappointing; CCS deployment ought to be seen as insuring the value of their very assets in a decarbonised energy system. In fact, the authors place all the responsibility for any CCS development and deployment solely on governments, i.e.to build the CO₂ transport and storage networks to their doorstep, upon which they might consider doing the CO₂ capture.

The report further distances European coal producers from any commitment to deploying CCS; the only technology that will allow such plant to operate in a low-carbon society.  “Plant operators will implement CO2 capture only if an appropriate transport and storage infrastructure is available that meets their capacity and cost needs in a timely manner.” The commitment of Euracoal to the development and deployment of CCS can and should be taken at face value. That is to say the European coal lobby has no recommendations or proposed measures to accelerate the deployment of CCS to reduce CO₂ emissions. Indeed Euracoal seems happy to tarnish the CCS storyline as being about defending the use of fossil fuels rather than a transformational tool as part of a low-carbon transition.

The repot claims that “improving the efficiency of Europe’s older coal-fired power plants where emissions of CO₂ can be reduced by 30% or more. EURACOAL estimates that total annual investment needed is between €5 and €10 billion across the EU, vastly lower than any alternative and with no hike in energy prices.” This clearly indicates how inefficient, decrepit and polluting the current stock of thermal coal power plants is. Due the laws of thermodynamics the use of Rankine cycle (steam turbine to generate electricity) the maximum theoretical thermal efficiency for a coal power plant is approximately 50%. A new coal fired plant will still provide electricity with a carbon intensity around twice that of a gas fired plant and nine times that of a CCS equipped facility. In essence, those emissions will remain far above a level that allows the EU to meet its stated climate ambitions.

Indeed in stating that CO₂ emissions from coal could be reduced by 30%, what the authors are calling for is a huge reinvestment in new unabated coal power plants to replace ageing and decrepit facilities. A new wave of unabated coal power investments is not compatible with any climate ambition, be it meagre, “realistic” or satisfactory.

Finally the report repeatedly refers to new less inefficient unabated coal power plants as “clean coal”. Such plants just remained tolerable with the addition of pollution control equipment for the reduction of particulates (causing respiratory illness), SOx and NOx (causing, among other damages, acid rain). Continuing to use the definition of “clean coal” from the 1970s is ridiculous almost 40 years down the line, at a point in time when the entire world is keenly aware that the emissions of CO₂ and GHGs pose the greatest inter-generational threat society has known. As all but the authors of the report seem aware, coal has no future in a European energy mix without CCS.

[1] Jaquelin Cochran, Debra Lew, Nikhil Kumar  (2013) Flexible Coal Evolution from Baseload to Peaking Plant

[2] IEA (2013) 21st Century Coal Advanced Technology and Global Energy Solution

[3] Communication From The Commission To The European Parliament And The Council European Energy Security Strategy {SWD(2014) 330 final}

[4] Bellona (2014) Ensuring energy supply security in Europe with CCS http://bellona.org/publication/ensuring-energy-supply-security-europe-ccs

[5] ZEP (2014) CO2 Capture and Storage for Gas Sustainable, low-carbon power for Europe

[6] Bellona (2013) Driving CO2 Capture and Storage in the EU http://bellona.org/publication/ccs-market-incentives-report

[7] Bellona (2011) CCS readiness at Šoštanj: Ticking boxes or preparing for the future?