So that means the first major climate policy we should adopt is not a cap-and-trade, but ...

Requiring all new coal power plants to meet an "emission performance" standard that limits CO2 emissions to levels achievable with CCS systems.

This is the 2007 recommendation of Ken Berlin and Robert M. Sussman in a Center for American Progress report [PDF], Global Warming and the Future of Coal: The Path to Carbon Capture and Storage (summary here). It is also the goal of a bill introduced last month by Waxman and Markey, "Moratorium on Uncontrolled Power Plants Act."

(Yes, regular readers will note that this does represent a bit of a shift in my thinking -- I once thought the most urgent climate policy was getting a price for carbon dioxide -- but the recent news from Europe about the possible resurgence of coal power should change everyone's thinking.)

The New York Times had a stunning report last week:

Over the next five years, Italy will increase its reliance on coal to 33 percent from 14 percent. Power generated by Enel from coal will rise to 50 percent.

And Italy is not alone in its return to coal. Driven by rising demand, record high oil and natural gas prices, concerns over energy security and an aversion to nuclear energy, European countries are slated to put into operation about 50 coal-fired plants over the next five years, plants that will be in use for the next five decades ...

There have been protests here in Civitavecchia [Italy], at a new coal plant in Germany, and at one in the Czech Republic, as well as at the Kingsnorth power station in Kent, which is slated to become Britain's first new coal-fired plant in more than a decade.

What is especially worrisome is that this is all happening at a time when Europe has capped its emissions and created a trading system for carbon dioxide resulting in a pretty serious price: €24.55 a ton, which is $38/ton of CO2, or $140 a ton of carbon -- real money!

And yet, as Berlin and Sussman assess U.S. politics climate politics:

In the current U.S. political environment, a cap-and-trade system is unlikely to result in a sufficiently high market price for CO2 (around $30 per ton) in the early years of a carbon control regime to assure that all coal plant developers adopt CCS systems. At lower carbon prices, plant developers could well conclude that it is more economical to build uncontrolled SCPC [supercritical pulverized coal] plants and then purchase credits to offset their emissions. A carbon tax that is not set at a sufficiently high level likely would have the same consequences.

I certainly agree with that assessment -- getting to $30 per ton of CO2 ($100/ton of carbon) in this country is not going to happen quickly. It could easily take a decade or more, a decade we simply don't have. And, of course, now we know that $30 per ton seems unlikely to stop traditional coal.

According to the Times, the scenario Berlin and Sussman warned about is occurring in Europe:

The European Union, through its emissions trading scheme, has tried to make power plants consider the costs of carbon, forcing them to buy "permits" for emissions. But with the price of oil so high, coal is far cheaper, even with the cost of permits to pollute factored in, Enel has calculated.

Certainly Enel's decision is incredibly shortsighted. The European permit price is obviously too low. Indeed, it is safe to say that the price must rise until building traditional coal plants is non-economic.

The policy framework

This could not, however, be a stand-alone policy. Obviously, this emissions standard would work only in the context of other policies -- including a cap-and-trade plus other incentives to accelerate renewables like concentrated solar power into the marketplace and an aggressive push to redesign state utility regulations to encourage energy efficiency and, ideally, cogeneration. Those policies will be the subject of a later part of this series.

Berlin and Sussman suggest that to give the new standard some flexibility, "all plants that begin construction after 2008 could be subject to the standard and would be required to implement carbon capture technology by 2013, and then to meet all sequestration requirements by 2016." They also suggest that "while CCS technology is being perfected, plant developers during the first three years in which the new performance standard is in effect could have the option to construct traditional coal plants that do not capture and sequester CO2 if they offset on a one-to-one basis their CO2 emissions by taking one or more of the following steps" --

• Improving efficiencies and lowering CO2 emissions at existing plants
• Retiring existing coal or natural gas units that generate CO2 emissions
• Constructing previously unplanned renewable fuel power plants representing up to 25 percent of the generation capacity of the new coal plant.

That simply goes too far for me. I don't want some utility building a brand-new (traditional) coal plant that could last for 50 to 80 years and "offsetting" that by shutting down some decades old coal plant that wasn't going to last many more decades anyway. No, if CCS takes a bit longer to develop than people hope, the country can certainly live without new coal plants for a few years -- especially if we have an aggressive energy efficiency and renewable energy deployment strategy.

And yes, it is entirely possible that CCS simply does not prove practical on a large scale or does not turn out to be a low-cost option. If so, coal has little future in this country. My best projection today (and I'll blog on this more later) is that CCS is going to be both less practical and more expensive than people think, that it certainly won't be the low-cost option, but the jury is out on whether it will be an affordable option.

So far, neither the administration nor the coal industry has done a very good job of pursuing the one that technology that can keep coal from extinction. Relatedly, the centerpiece climate legislation in the Senate does not do a good job of promoting CCS cost-effectively -- see "Maximizing Carbon Capture and Storage Under the Lieberman Warner Global Warming Bill."

I certainly endorse a strong effort to find out as quickly as possible if coal with CCS can deliver significant quantities of affordable carbon-free power, such as Berlin and Sussman suggest:

• An enhanced R&D program for capture technologies at both SCPC and IGCC [Integrated Gasification Combined Cycle] facilities to reduce the costs of capture as quickly as possible
• An accelerated program to gain large-scale experience with sequestration for a range of geologic formations
• A comprehensive national inventory of potential storage reservoirs
• A new regulatory framework for evaluating, permitting, monitoring, and remediating sequestration sites and allocating liability for long-term CO2 storage.

The bottom line is that we need an immediate moratorium on the construction of new traditional coal plants. That is a higher priority than a cap-and-trade bill, although such a bill is also a high priority. If the West cannot stop building such coal plants and quickly show the world that multiple alternatives -- particularly efficiency and renewables -- are practical and affordable, then how will we be able to convince the developing world, especially China and India, to stop building such coal plants within the decade?

Politically possible?

Is such a moratorium politically possible right now? That is unclear -- but it must be pointed out that Sen. Obama's excellent climate plan says:

Obama believes that the imperative to confront climate change requires that we prevent a new wave of traditional coal facilities in the U.S. and work aggressively to transfer low-carbon coal technologies around the world ...

Obama will use whatever policy tools are necessary, including standards that ban new traditional coal facilities, to ensure that we move quickly to commercialize and deploy low carbon coal technology. Obama's stringent cap on carbon will also make it uneconomic to site traditional coal facilities and discourage the use of existing inefficient coal facilities.

Clinton's excellent plan aggressively pushes demonstration of CCS, but does not appear quite as strong as Obama's: "She will require all new coal plants to be capable of adding capture and storage technology when it becomes commercially available." That is not good enough, since it will be quite expensive for the vast majority of plants to make such retrofits if they don't integrate actual CCS into their design and construction.

As for McCain, well, he has no plan yet, so he isn't even at the table yet.

Finally, the failure to stop building coal without CCS over the next few years is not fatal to achieving 450 ppm -- but it would mean that unless someone comes up with a practical and affordable post-combustion CCS technology, most of those coal plants plants will have to be shut down before the end of their normal lifetime, possibly much sooner. And would be not merely politically unpopular, but a tremendous waste of capital that should be avoided at all cost.

This post was created for ClimateProgress.org, a project of the Center for American Progress Action Fund.