Compliance Strategies for Proposed Greenhouse Gas Rules in Existing Power Plants

Ryan Bliss | Jul 14, 2014



On June 2, 2014, the Environmental Protection Agency (EPA) issued its Clean Power Proposal for reducing CO2 emissions from existing plants in accordance with Section 111(d) of the Clean Air Act.  The agency’s goal is to reduce CO2 emissions from existing power plants by 30% from 2005 CO2 emissions levels by 2030.  The proposed regulations provide the states with unprecedented flexibility to achieve compliance through the use of four building blocks:

 - Unit-specific efficiency improvements;

 - Re-dispatch from coal-based to natural gas-based units;

 - Expanded use of low- and zero-carbon generating capacity; and

- Expanded use of demand-side energy efficiency.

  The EPA has initiated a one-year comment period for the proposed regulations ending in June 2015.  States would prepare implementation plans by 2016, with EPA acceptance of the state plans scheduled for 2017.  Compliance would be phased in over the period 2020 through 2030.  Unit-specific efficiency improvements and demand side management represents significant compliance opportunities for owners of coal-fired power plants. Moreover, in addition to the four building blocks proposed by the EPA, we believe that CO2 emissions can be reduced further through the use of cap-and-trade programs and improved transmission system efficiency.

Unit-Specific Efficiency Improvements

Coal is responsible for producing 40% of the world’s electricity, as well as 39% of its CO2 emissions.1 As illustrated in the table below, there are several different variations of coal, all of which produce more CO2 emissions than natural gas. 

CO2 Emission Factors

Type of Fuel

Heating Value2

CO2 Emission Factor3

(lb. CO2/MMBtu)

Sub-bituminous Coal

8,300-13,000 BTU/lb.


Bituminous Coal

10,500-14,500 BTU/lb.



~15,000 BTU/lb.



4,000-8,300 BTU/lb.


Natural Gas

17,500-22,000 BTU/lb.



Coal-fired power plants (CFPPs) use steam turbine technology, which is significantly less efficient than modern combined-cycle gas turbine technology.  Coal/steam technology efficiency has improved from nominal levels of 11,000 BTU/KWh, but it is still not as efficient as combined-cycle gas turbine technology efficiency, which is less than 7,000 BTU/KWh. 

Over the past several years, environmental regulations have dominated discussion about CFPPs.  Energy efficiency has received less attention.  In 2009, the National Energy Technology Laboratory sponsored a workshop titled “Opportunities to Improve the Energy Efficiency of Coal Fired Power Plants.”4  Workshop participants included representatives from owners and operators of CFPPs, equipment manufacturers and engineering firms.  The workshop group found that energy efficiency varied significantly among CFPPs and that efficiency could be improved by as much as 10%. 

Some owners of CFPPs have focused on energy efficiency improvements and implemented best management practices.  Others may have focused attention on regulatory impacts and deferred energy efficiency improvements.  We encourage owners and operators of CFPPs to audit energy efficiency at each of the units that are scheduled to remain in service, and implement changes that are technically and economically feasible.   

The EPA expects unit-specific energy improvements in the range of 4% to 6%, which would help achieve the goal of reducing CO2 emissions by 30%. However, adding pollution control technology to existing coal plants generally decreases energy efficiency.  Among the pollution control technologies currently receiving the greatest attention is carbon capture and sequestration (CCS). Existing CCS technologies are very energy intensive and would consume as much as 30% of the energy produced by a coal fired power plant.  Although the EPA has not proposed CCS as a building block for CO2 reduction at this time, research into the technology continues both in the U.S. and internationally.

In order for a supercritical pulverized coal plant to comply with the EPA’s proposed new standards, its CO2 emissions would need to decrease by 40%.  There currently is no way to accomplish this without using CCS.  With CCS, the waste CO2 is removed from the coal plant’s emission stream and then stored at a “sequestration” site. One key problem with the use of CCS is that the process would use a large percentage of a plant’s energy output, and would be a cost burden to both producers and consumers.

Currently, the energy required to remove CO2 from a source’s emission stream is about 30%5, but it is not yet possible to capture and store CO2 on the scale of a large coal plant. If CCS technology were perfected to allow for its use at large coal plants, electricity costs would increase significantly, despite the fact that nearly 95% of them are located within 50 miles of a CO2 sequestration site. 

Four different types of carbon capture methods are being researched and tested, including post-combustion capture from coal plants using amines; pre-combustion capture from integrated gasification combined cycles (IGCC); oxy-combustion capture from pulverized coal; and post-combustion from natural gas combined cycles.6

One of the first large-scale experiments with CCS in the U.S. began in 2009 when American Electric Power’s Mountaineer Plant in West Virginia attached a chemical plant to its power plant in order to capture and store CO2.  During a two-year span, more than 37,000 metric tons of CO2 were captured, compressed and stored underground.  In 2011, climate change legislation that would have required this CCS approach failed in the U.S. Senate, thus ending the project. In North Dakota, one plant is capturing CO2 and transporting it to Saskatchewan for storage in oil reservoirs. The main concerns with underground storage of CO2 include the possibility of leaks that could harm humans and the environment as well as the chance that earthquakes could be caused by injecting CO2 into areas where rock is brittle and faulted.1 

China burns nearly as much coal as the rest of the world combined, and has taken the lead on CCS technology. The state-owned utility, China Huaneng Group, along with many other partners including Missouri-based Peabody Energy, has built the GreenGen facility in Tianjin.  Valued at $1 billion, GreenGen was developed to extract CO2 from a CFPP and store it underground.  A similar effort launched by Shenhua Group – the Wulanmulun project – is under way in Mongolia. The Wulanmulun facility converts coal into a liquid form and then stores it in an underground saltwater aquifer. 

Despite these advances, no facility in the world currently captures and stores carbon emissions on the scale of a large coal-fired power plant.  The CCS process will use a large percentage of a plant’s energy output, and will lead to significant additional costs for both producers and consumers.  However, investments in this technology are necessary if the world is going to continue to burn coal.7

Demand Side Management Programs

The EPA’s Clean Power Proposal guidelines include Demand Side Management (DSM) as the second potential compliance path available to states and utilities.. Unlike reducing source emissions or improving transmission systems, DSM focuses on reducing usage on the customer side of the emissions process. Improving energy efficiency or reducing demand at the point of use translates directly to reduced generation at the power plant.  The keys to implementing DSM will be verification of the energy savings and the translation of those savings into greenhouse gas (GHG) reductions.

The good news is that the connection between improved DSM and reduced GHG emissions has been recognized, calculated, tracked and reported on for decades. The U.S. Department of Energy has developed internationally recognized protocols that have been used since 1995 on both federal and non-federal projects to measure and verify actual energy savings. The EPA has developed and regularly updates a list of regional factors that translate electric generation into GHG emissions based on the active generating plants specific to each region. In other words, both the ability to verify energy savings and the ability to translate those savings directly into GHG emission reductions are already in place and accepted in federal contracting.

Cap-and-Trade Programs

Cap-and-trade programs are another compliance strategy that states can use to comply with the new standards.  The Acid Rain Program and Clean Air Interstate Rule (CAIR) are two examples of cap-and-trade programs that have successfully lowered SO2 and NOx emissions.  The Acid Rain Program has resulted in a 40% decrease in SO2 emissions since the 1990s and a 65% decrease in acid rain levels since 1976.8  CAIR consists of three separate trading programs: an annual NOx program, an ozone season NOx program, and an annual SO2 program. 

In 2011, CAIR was replaced by the Cross-State Air Pollution Rule, which aims to reduce emissions that contribute to ozone and fine particle pollution.9 This type of cap-and-trade approach could be used with coal to reduce CO2 emissions.  Each state would have its own emissions cap based on the primary type of fuel used.  States with more coal-based electricity would have a higher cap that could be reduced in phases over time.  Emission credits could be stored or traded within a state’s electric system.  These programs would shift the burden of electricity generation to lower emitting plants that would run more often, thus decreasing emissions in the state and nationwide.

Transmission System Efficiency Improvements

Emission levels also can be lowered through efficiency improvements in the bulk power delivery process, which involves moving electric energy across the grid over large distances to specific locations.  There are three primary causes for inefficiency in this process. First,  approximately 6% to 8% of the energy is lost during bulk delivery due to thermal friction depending on voltage and conductor size.  While these percentages may seem small, this inefficiency can wind up costing billions of dollars.  Another form of inefficiency in power delivery is transmission congestion, which occurs when electricity flow is restricted due to capacity limits or safety constraints within the grid.  When this happens, a system operator is forced to find alternative electrical paths, often from a less efficient resource.  Finally, a number of U.S. power generation facilities have been labeled as “reliability must-run” plants, and are required to operate regardless of their efficiency to maintain voltage levels within large urban areas.

Several technologies have been developed to offset energy losses in transmission systems by relieving transmission congestion.  High voltage direct current (DC) lines are replacing alternating current (AC) lines due to the fact they have 25% lower line losses, two to five times the capacity, and the ability to control the flow of power more closely.  Flexible AC Transmission Systems, or FACTS, stabilize voltage, which allows lines to be loaded more heavily, thus increasing usage by 20% to 40%. 

Transmission lines, which operate more efficiently at higher voltages, could be made more efficient simply by knowing more about the current conditions of each individual line at a given time.  Energy is often lost during the time between production and delivery due to factors such as wire resistance, weather, and operating electrical load.  However, improvements in efficiency can be made by allowing for more grid flexibility and having a better understanding of the exact location and behavior of the lines. 

Shifting to a dynamic line rating monitoring system will enable greater utilization of higher voltage lines by increasing the capacity of lower voltage lines.  This system allows for better utilization by including computer software that determines the capacity of a transmission line based on real-time monitored clearances and conductor temperature. Using this thermal monitoring, operators would then be able to change the load of certain lines as necessary in order to prevent a short circuit.  Through these advances in transmission and delivery efficiency, more energy would reach its intended destination without being lost. In the long run, this would lessen the energy that needs to be produced.


The EPA’s new draft greenhouse gas regulations have the potential to result in meaningful CO2 reductions through the use of flexible building blocks.  Additional tools for achieving CO2 reduction will be identified during the comment period and developed during the implementation period.  Currently, the states are focused on reducing emissions at the combustion source through carbon capture and storage and cap-and-trade programs, as well as through demand side management and efficiency improvements in the transmission system. Advanced technology and creative thinking will make it possible to lower emissions while still providing citizens with stable and reliable energy supply.  We encourage the EPA and the states to explore all available options – including cap-and-trade programs and improved transmission system efficiency – as they develop and implement their compliance strategies. 

Works Cited:

1 Nijhuis, Michelle. "Can Coal Ever Be Clean?" National Geographic (n.d.): n. pag. Web.

2 Coal. Rep. N.p.: Center for Climate and Energy Solutions, n.d. Web. <>.

3 United States of America. U.S. Energy Information Administration. FAQ: How Much Carbon Dioxide Is Produced When Different Fuels Are Burned? N.p.: n.p., n.d. Web.

4 Eisenhauer, Jack & Scheer, Richard. National Energy Technology Laboratory. Opportunities to Improve the Efficiency of Existing Coalfired Power Plants

5 United States of America. Congressional Research Service. EPA Standards for Greenhouse Gas Emissions from Power Plants: Many Questions, Some Answers. By James E. McCarthy. N.p.: n.p., 2013. Web.

6 International Energy Agency. Cost and Performance of Carbon Dioxide from Power Generation. By Matthias Finkenrath. N.p.: n.p., 2011. Web.

7 Mann, Charles C. "Renewables Aren't Enough, Clean Coal Is the Future." Wired n.d.: n. pag. Web.]

8 "Acid Rain Program." Wikipedia. N.p., n.d. Web. <>.

9 United States of America. Environmental Protection Agency. NOx Budget Trading Program- Basic Information. N.p.: n.p., n.d. Web. 


Related Topics


An excellent article! My congratulations on bringing a professional outlook into this forum, which has, of late, been peppered with parochial views of the traditional power generation fleet.

Conversion of our energy picture from 19th & 20th century technologies to 21st century ones will take decades, and should not take any longer than that. As your fuel chart shows, coal is the biggest danger at this time, and the sooner we can convert to generation with a smaller carbon footprint, the better. By 2100, the carbon footprint for power production is going to have to be below 10% of what it is now, and the same for transportation. And not just for America, but globally...

Now, dear Authors, please be prepared to rebut the onslaught of, ahhhh, "contrary views" shall we say? I could use a little company ;-)

I am also attempting to garner one 5-minute slot to speak at the Washington EPA session at the end of this month. The purpose will be to encourage the EPA to help the states provide all of their energy producers with a fair ROI for investments in efficiency improvements.


Economic, scientific and environmental nonsense.

Pumping stupefying amounts of liquid CO2 into the ground is completely insane. There is no way in hell that could withstand a proper environmental impact assessment, except perhaps in parts of the "oil patch" where the technique is currently in limited use.

The bus-bar cost of a coal plant using "sequestration" is also stupefying. Easily several times that of new coal plants.

Increased transmission voltages??? The cost would also be stupefying with essentially non-existent impact.

The EPA's proposed regulations are utterly irrelevant to global CO2 levels. Simple math demonstration of total world input versus alleged US reduction.


I'll be blunt: you folks have no idea what the hell you are talking about.

Mr Keller,

Agreed - CCS at-the-plant is a colossal waste of energy, and R&D $ going for nothing. The only places where it would be on any use would be to provide CO2 for enhanced oil recovery, for the expressed purposes of pumping up yet MORE fossil carbon for combustion and exhaust into the atmosphere. A pretty poor way to go, both from an economic and an environmental standpoint.

Transmission voltages are controlled by adjustable taps on transformers to control power flow and direction, as well as manage line stability. The industry is always driving forward with higher line voltage technology in order to ameliorate line losses, and reduce cable costs. HVDC and AC transmission systems routinely go over 500kv now for new long-distance projects. HVDC operates at half the losses of similar AC systems, with the added benefit of having submersible/buriable cables.
We have recently engaged in projects at 800kv+.

The EPA's proposed regulations ARE important. First, of course, they will help reduce US total emissions about 10-15% (when you consider all sources including transportation). That's a good start.
Second, it eliminates all global arguments that begin with something like "We won't do anything until the USA takes some significant steps to reduce THEIR CO2 emissions, which are still the largest on the planet."

If you look at climate disruption as being as serious a threat to humanity as WW1, WW2 or more likely, smallpox, and the US role in ending each of those "problems", it may give you a clearer picture of why WE need to use our "powers of persuasion". If the US had not fought hard in any of those three campaigns, the outcomes would surely have gone the wrong way.

WW1: 15M deaths
WW2: 66M deaths
smallpox: 300-500M deaths (1900-1979)

The general population does not feel any imminent threat ... yet. In industry, tt is the goal of a pro-active maintenance approach to detect incipient problems and take remedial measures BEFORE the catastrophe happens. We should be doing the same with the global environment.


Tap changes on transformers are typically made because of problems with properly supporting the grid (generally protective relay issues) and are utterly inconsequential to CO2; impact is too small to even register.

High-voltage transmission lines are expensive to upgrade; the wire would generally have to be up-sized; the line is now heavier which impacts towers; the transformers have to be changed out. The bang-for-the-buck, vis-a-vis CO2, is just not worth it.

Persuading people to go along with the EPA's delusional thinking is equally delusional.

Industry solves real problems while relying heavily on cost effective solutions. The complete opposite of the EPA.

The EPA is a rogue government agency that has manufactured a crisis largely to increase the power of the radical left. The trajectory of planets's actual temperature does not support the hysteria they are attempting to promulgate. There is simply no creditable actual temperature data that supports the theory man is creating catastrophic changes to the climate by emitting CO2.

The method by which the EPA has chosen to implement these reductions is to let the marketplace decide, i.e. the states and the fleets residing within the states. Very similar to transportation CAFE standards. Set the bar and let the participants choose the method of compliance.

I will be speaking at the EPA open hearings in DC, and encouraging them to help the states remove barriers to investment in energy efficiency within the power generation industry. Right now, there are many state-implemented utility commission barriers, designed decades ago to hold down residential electricity rates to the tune of a few dollars a month, which basically shift utility investment AWAY from efficiency improvements. That has really got to stop now. If a utility invests in fleet performance improvements which inherently reduce emissions, they should be able to enjoy a reasonable ROI on those investments, and the consumer should not be insulated from bearing some of the cost responsibility for emissions remediation. It is being done for their benefit after all, isn't it?

Credible temperature variations AND other climate disruptions are trending, and have been trending for over a century. Atlantic basin named storms, hurricanes and major hurricanes have all been trending upward for the past 100 years, right along with increased CO2 and the associated temperature rises.
Again, it is a very noisy signal during this time period. Are you simply not going to be convinced until the signal-to-noise ratio gets better???


Perhaps you have missed it, but the dire predictions of more hurricanes never materialized.

The climate is too complex and non-linear to make any kind of future predictions; might as well use a Ouija board.

Forcing industry to spend money and not even materially affect a problem that is highly speculative is just plain dumb. The proper approach is to use energy wisely, which inherently reduces emissions and saves money. Embarking on the EPA's ill-conceived program will only significantly increases cost and put additional needless financial burdens on the already ever-poorer middle-class.

If the Chinese are taking the lead in CCS I say great - who knows what they may come up with. But the Swedish firm Vattenfall was going to save Germany with CCS, and what happened was that they had a wonderful time spending Money, but not coming up with anything that made sense. But even so I rate their efforts a plus, because it became clear that they were a bunch of crooks and it will not be easy for them in the near future at least to find an audience dumb enough to listen to their CCS nonsense..

CCS is a great research avenue to keep alive in university and corporate labs for decades longer - who knows what useful technology eventually might spin off from this otherwise unviable endeavor. Oh, and the fossil industries should be the ones footing most of the bill, not the taxpayers through NERL or agencies.

Mr. Keller - more hurricanes and typhoons, over the decades, HAVE occurred. You just aren't counting. NOAA is counting, as I recently showed in another set of article comments - please note the uptrends in all three Atlantic storm categories: named storms, hurricanes, and major hurricanes:

Uptrends are precisely coincident with uptrending atmospheric CO2, and show little correlation with the solar cycles over the same time period. I suggest you take 60 seconds and look at the charts...
The effects of climate disruption aren't showing up as step changes from year to year. They are occurring and accumulating at a pace generally too slow to see from the standpoint of one individual's scope of view, and lifetime. However, the changes ARE clear within the records kept over three lifetimes, or six generations 1850 to present. The data is noisy, somewhat variable from year to year, even decade to decade ... but the trends ARE clear, and the explanations are virtually undeniable, except by a died-in-the-wool denialist.

As far as burdening the middle-class: the middle class regularly self-imposes much higher burdens on itself for far more frivolous pursuits. What has your cable bill done over the past 30 years? What have your personal expenditures for telecom (i.e. cell phone) done over the same time period? In each of those cases, what was really wrong with the OLD way we handled those issues? How about purchases of personal electronic devices - some people have half a dozen or more. Yes they are useful, and fun, and may improve personal safety, productivity, etc. But all these applications pale in comparison to the imperative of not trashing the planet we live on to the point where the general population and our existing lifestyles are severely threatened. We spend trillions on wars where similar threats are less credible, but perceived as more immediate and politically viable.

I am in the middle class, and don't feel the least bit threatened or feel the least bit of economic apprehension about addressing CO2 emissions NOW. By the time 2030 rolls around, with business as usual between now and then, the costs will scare a lot of people, and rightly so.

The difference is choice, as opposed to unelected bureaucrats dictating regulations that are nothing more than religious fervor unable to measure up to withstand sound science.

I still find it extremely interesting that no one seems to realize that the molecular weight of CO2 is 44.01 and air is about 28 and there is no way in the physical world that CO2 gas will "Rise" into the atmosphere. It will sink like a rock to the ground. The CO2 in the upper atmosphere is more likely from volcano emissions. I developed a coal fired boiler optimization program many years ago that significantly optimizes the combustion process. I am close to doing a demonstration in China and have met with about 20 different plants over the past years in China. Eliminating CO2 from combustion is like telling Hersheys to make the Kisses without chocolate or calories.

I guess if you are a politician you have the luxury of not being limited by reality.

Economics of Carbon Capture Sequestration vs. Natural Gas Power Plants
About two years ago, Indiana Utility Regulatory Commission (IURC) recently placed a $2.595bn “hard cap” on the construction on Duke Energy’s proposed Edwardsport 630 MW integrated gasification combined-cycle (IGCC) power plant. As of June 2012, Duke Energy expects it will be the fourth quarter of this year and perhaps early 2013 before the $3bn-plus Edwardsport IGCC project in Indiana begins normal commercial operation. This plant’s unit capital cost = $4800/KW compared to Southern Company’s Carbon Capture Sequestration [CCS] Kemper plant capital costs translate to $15000/KW for new cost of coal-fired plant with CCS.

Kemper Project is the one of the few ‘tires to kick’ for operating CCS technology which is inherent to USEPA’s proposed Carbon Control legislation i.e. how can utilities be expected to implement technology that has not been commercially demonstrated i.e. BACT. Using Kemper’s costs are suitable since EPA has cited Kemper as a reference CCS installation

Petra Nova project’s generation capacity = 240 MW and its capital cost = $1 billion in investments or $4167/KW. Sunflower Electric Holcomb II proposed 895 MW coal-fired plant without CCS would cost $3128/KW or CCS increases capital cost by at least 30%. Since neither plant is in operation Petro Nova’s costs are investments to-date while Holcomb II costs reflect estimates in last year’s dollars.

FPL’s Natural Gas Port Everglades capital cost = $978/KW similar to Louisville G&E Green River plant CAPEX cost of $1000/KW. Compare these costs to proposed, new coal-fired plant [Kansas] =$3128/KW or coal-fired plant retrofit with Carbon Capture and Sequestration = $4167/KW. So why would an electric utility opt to build a new coal-fired power plant at a 30% premium for CCS, while for, at least, less than 30% a new Natural Gas Combined Cycle could be constructed?

This is why Duke Energy is also proposing to build Natural Gas plants to replace their coal-fired units at Crystal River FL.
Richard W. Goodwin West Palm Beach FL

Mr Keller, even if your arguments about global warming being insufficiently supported by the available science were correct, you have ignored the elephant in the room - ocean acidification. This one concern, by itself, is more than sufficient to justify EPA's CO2 emission reduction strategy.

I suppose you might respond by arguing that people reliant on the ocean for sustenance or livelihood should find other jobs, or other sources of protein. But the "let them eat cake" platform in support of business as usual has already proved to be, ahhh, shall we say, unpopular.

If we ever put a price on ocean acidification, business as usual with respect to CO2 emissions will look not just uneconomic, but criminal.

Question - now that some discussion is beginning to take a more realistic turn - CO2 in the oceans instead of CO2 in the atmosphere - Have the scientists reviewing this info been able to separate out how much of the CO2 comes from the massive forest fires the US has experienced over the past 2 decades?

It seems that every time you turn on the news there is another record breaking forest fire. Also, since the Pacific Ocean has thousands of miles of undersea fissures that are spewing lava into the ocean floor continuously which is dissolving SO2 and many other chemicals into the ocean water. Arguing that CO2 is causing the ocean surface waters to become slightly less basic might be true but since there are many large alternative sources for the CO2 it should compel these scientists to determine the real amount of coal fired plant contribution after subtracting out the amount of CO2 created in combustion in steam plants from the CO2 created by all engines - from cars and motorcycles to trains and buses and planes compared to coal fired plants. Then factor out how much of the CO2 settles on land and never makes it to the oceans.

It seems to me that it is a very tiny percentage that we can affect if they totally eliminated it and put us back to the 1920s in terms of available electricity. And we are only wanting to spend trillions of someone else's money to achieve this tiny tiny adjustment.

Mr. Mizzell,

You may have some very good engineering skills, but you need to brush up on your physics and physical chemistry.

The atmosphere is a mixture and solution of many gases. At existing temperatures, these gases will not stratify as you suggest. If your hypothesis was correct, all of the CO2 (wt 44) then all the argon (wt 39) would be at ground level and we would not be able to breath. CO2 is present at levels around 400ppm, and argon is at 9000 ppm (not a typo!) It should be patently clear that this is NOT the case, yes?

You might also note that reference CO2 measurements are not made at sea level, but at altitude: Switzerland's measurements are taekn at about 12,000 feet, and at NOAA's from Mauna Loa at nearly 14,000 feet. Both locations are well above at least 1/3 of the bulk of our atmosphere, as atmospheric pressure at 12000 feet is 9.5 psi, and 14000 ft is 8.9 psi (sea level is 14.7psi).

Let's calculate a CO2 dump from a year's worth of major wildfires - first with a reminder that THAT carbon was harvested FROM the atmosphere, typically over just a decade or few, and not from eons-old carbon from fossil-fuel deposits.

In the US, total acreage destroyed on an annual basis over the past two decades has ranged from 3.5 to almost 10 million acres. Wildfires destroy grasslands, scrublands and forest, but mostly the latter two in terms of acreage. Let's say, for the sake of argument, that five tons of carbon*, or twelve tons of CO2, are liberated per acre during a wildfire. This would mean that US wildfires liberate from 42 to 120 million tons of CO2 per year.

Our fossil fuel consumption, just the US alone, dumps about 8 BILLION tons of CO2 into the atmosphere, nearly 70 times as much as our conservatively high estimate from wildfires.

There are estimates of the amount of our global fossil emissions that are taken up by nature, with the balance being added to the atmosphere. At this time, global emissions are in excess of 31GT per year, with about 2/3 of that going into the atmospheric load. This is what is causing the measured CO2 ppm levels to go up at about 4-5ppm per year over recent years. How do we know where this CO2 is coming from, you might inquire. By looking at historical levels of the ratio of C13 to C12 in the atmosphere. Over the course of the last several thousand years, that ratio has continued to increase, as C12 is (and was) favored by plants for capture thru photosynthesis. If plant uptake favors C12, photosynthesis on land and at sea would tend to reduce C12, but we see that C12 is actually on the increase instead. Source? Liberation of C12 from fossil fuels, which were originally plant matter, especially coal and oil.

Further "backup" if you will, for the source of CO2 being fossil carbon combustion is the minute but detectable steady decline of atmospheric O2:

This is a worthwhile presentation to go through - not much narrative, just charts, and a few photos and illustrations.


* I estimate conservatively, using 1 lb per sq ft vegetation burned, 60% moisture content, 50% Carbon by dry weight, and 44000 sq ft per acre - 4.4 tons C per acre. Rounded up to 5 tons per acre.

There is no possible way CO2 will EVER make the ocean acidic; basic chemistry 101. The oceans suffer from all the crap we dump into them, with CO2 being a complete non-problem in that regard.

CO2 is a trace gas and we simply do not know if it is able to materially impact the climate. We do know, however, the climate models that created the current hysteria are completely wrong. The predictions of significant temperature increases have not occurred.

Mr. Keller,

Why can't you understand the difference between "acid" and "acidification"?

If I lower the pH of any liquid, I am acidifying it, even if it is basic in nature.
If I take a weak base aqueous solution of pH 8.5, bubble in some CO2, under the
assumption that it does not form a precipitate, and the pH goes down to 8.3, then
I have, BY DEFINITION, "acidified" it - I have lowered its pH.

Yes, you are correct that the oceans will not go to a pH below 7, such that they
are acid in the whole. However, they ARE acidifying, dropping about 0.10 in pH
so far, and are headed to below 8.0 at current rates of acidification. This will be
deadly to many important forms of marine life.

Why do denialists put up straw man semantical arguments instead of focusing
on real data? Because they can!

The use of "acidification" is a deliberate attempt at deception to scare folks. The proper term is less basic.