Rachel's Democracy and Health News #945, February 7, 2008


[Rachel's introduction: The powerful "Group of 8," or G8, nations in 2005 endorsed a plan to avert global warming, and the plan is being executed now. Can it work?]

By Peter Montague

When the leaders of the "Group of 8," or G8, nations held their 31st annual summit in July 2005 at Gleneagles, Scotland, their top agenda item was a "Plan of Action" for climate change. (The Group of 8 is an exclusive club that includes only Canada, England, France, Germany, Italy, Japan, Russia, and the U.S.)

At the Gleaneagles summit, the G8 nations committed themselves to a "Plan of Action -- Climate Change, Clean Energy and Sustainable Development." Paragraph 14 of the G8 Plan says, "We will work to accelerate the development and commercialization of Carbon Capture and Storage technology." These 15 words unleashed a torrent of global investment, which rapidly created an infrastructure devoted to "carbon capture and storage," or CCS as it is now known.

The idea behind CCS is that carbon dioxide (CO2) is the main global- warming gas and to keep the planet from warming to dangerous levels, there are two basic approaches:

1. Prevention: Don't make so much CO2. Or,

2. End-of-pipe filters and traps: Continue making CO2 but capture it, and somehow keep it out of the atmosphere forever. This is CCS, also known as "clean coal."

The point of "carbon capture and storage" (CCS) is to continue making CO2 gas but capture it, convert it into a liquid by pressurizing it to at least 1500 pounds per square inch, transport it to a suitable location (by pipeline or ship), and then inject it under pressure into the ground, hoping it will stay there forever.

The G8 Plan of Action contains many other commitments besides CCS (green buildings, cleaner cars, etc.), but CCS was the one that the world's dominant energy corporations (coal and oil) embraced enthusiastically. Instead of investing in a rapid shift away from fossil fuels to carbon-free (and nuclear-free) sources of energy (basically solar power in its many forms, plus geothermal and tidal power), the G8 CCS Plan allows the coal and oil industries to extract fossil fuels until there are no more fossil fuels left to extract, process them (by burning, gasifying, or liquefying them), and bury the resultant trillions of metric tonnes of hazardous CO2 wastes deep in the ground, hoping it will all stay there forever. (A metric tonne = 1000 kilograms = 2200 pounds.)

The G8 CCS Plan is by far the largest hazardous waste disposal project ever envisioned (and this assessment does not include the 117 million metric tonnes of solid hazardous coal combustion wastes [CCW] produced each year by the U.S. coal industry,[1] or the major ecological disruption created by coal mining, mountain-top removal, acid mine drainage, and so on).

The International Energy Agency estimates that, to make a dent in the global warming problem, we will need 6000 CCS projects, each injecting a million tonnes of CO2 a year into the ground.[2] And this will be just a beginning -- to bury 10 trillion tonnes of CO2 during the next 150 years would require 67,000 projects each injecting into the ground a million tonnes of hazardous CO2 each year.

The main purpose of such a Herculean hazardous waste disposal project would be to allow the coal and oil industries to continue to gain outsized returns on their historical investments without having to worry about any new fangled renewable energy technologies like solar, wind, geothermal, or tidal power. If CCS gets going on the scale envisioned in the G8's global "Plan of Action," renewables will not be needed.

In sum, CCS provides a "get out of jail free" card for the coal and oil corporations for at least the next century -- and throws a major monkey wrench into their competitors' plans to attract investment for renewable energy.

Is CCS a good idea?

Here are 20 reasons why it may not be:

1. CCS will eliminate incentives for renewable energy

As noted above, CCS will eliminate incentives to develop renewable sources of energy. Every dollar spent on "clean coal" is a dollar that cannot be spent developing renewables. CCS will pull the investment rug out from under renewable energy. Indeed, that is the main point of CCS.

2. CCS will undermine progress toward Green Chemistry

As coal executives remind us (4 Mbyte PDF), global oil production peaked in 2005 and has begun to decline. They say the future belongs to coal because from now on it's downhill for oil production, and this means oil prices will be more-or-less-steadily rising. Here, coal executives see coal coming to the rescue. Using well-developed technologies that powered the Nazi blitzkrieg during World War II, coal can be turned into liquid fuels for transportation. Furthermore, coal could also replace oil as the main feed stock for the chemical industry. Using coal in this way produces roughly twice as much waste CO2 as burning it to make electricity, but with CCS, who cares? Under the G8 Plan, it will all be buried a mile below ground, out of sight and very likely out of mind.

Using coal as a chemical feedstock violates one of the 12 Principles of Green Chemistry -- that feedstocks should come from renewable, not depleting, resources. By violating this basic principle, the CCS Plan will set back green chemistry by many decades and divert investment away from a waste-free, sustainable chemical industry.

3. CCS will create a perpetual threat of leakage

Leakage from underground sites will remain a perpetual threat, a major concern for all civilizations, a sword of Damocles hanging over the future.

The size of the CCS CO2 hazardous waste disposal problem is staggeringly large. If 80% of the world's remaining coal were burned, at least 10 trillion tons of CO2 would be created. (If some of it were converted into liquid fuels or chemical feedstocks, the waste CO2 produced would be even larger.) Ten trillion tons of CO2 represents 10 times as much CO2 as was emitted worldwide during the entire 20th century.[3] Anything more than the most trivial leakage could cause dangerous -- even catastrophic -- global warming.

The Intergovernmental Panel on Climate Change (IPCC) has pointed out that leakage and fugitive emissions can be expected from all five parts of a CCS the system -- (1) capture; (2) pressurization and liquefaction; (3) transport; (4) injection; and (5) perpetual storage.

If even a tenth of a percent of the CO2 were to leak from the system annually, the resultant buildup of global-warming gas in the atmosphere would reach dangerous levels, plausibly ruining the Earth as a place suitable for human habitation. At best, "clean coal" with CCS is a "monstrous gamble"[4] with the future of planet Earth and all its inhabitants.

4. Ethically, do we have a right to threaten the future?

A related question arises: Given that relatively benign and safe alternatives exist, is it ethical for us to saddle all future humans with a sword of Damocles consisting of billions or trillions of tonnes of hazardous waste CO2 buried in the ground? What legal and ethical authorities can we cite to justify such unprecedented -- and deeply antisocial -- behavior?

5. Perpetual storage of waste is beyond all human experience

CO2 will have to remain buried underground forever. Humans have no experience engineering anything intended to last forever. Engineering projects expected to last "in perpetuity" fall in a realm beyond all human experience. How can we develop confidence that engineers can design systems that are robust and error-free that will endure in perpetuity? How can we ever settle the question, "What if the 'clean coal' engineers are wrong?"

Is it plausible that the world's engineering community could make a colossal error?

In 2005, the Intergovernmental Panel on Climate Change (IPCC) issued a report (24 Mbyte PDF) devoted to the subject of carbon capture and storage. In it, this blue-ribbon body of leading scientists and engineers described pumping CO2 into the oceans, creating a "lake" of CO2 on the ocean floor. Clearly, the IPCC considered ocean disposal a viable option.

That was in 2005. Less than three years later, we know that ocean disposal of CO2 would be a catastrophic error because it would lower the pH of the oceans, severly disrupting the marine food web.[5]

Yes, even the combined knowledge and judgment of the world's elite Nobel-prize-winning scientists and engineers can be catastrophically wrong. Given that there are excellent, available alternatives to CCS, why should we accept this monstrous gamble?

To cite but two other examples of colossal errors by the world's most sophisticated technical elites:

** It is fundamental to bench chemistry that if you are aiming to manufacture a novel compound, you choose a suitable container in advance. Every chemistry freshman knows this. Nevertheless, the world's atomic scientists pressed ahead with world-wide deployment of the civilian nuclear reactor system without ever answering the question, how will the radioactive wastes be contained? Sixty years into the enterprise they still have not reached consensus on a satisfactory answer.

** During the 18 years 1945-1963, U.S. nuclear weapons scientists and engineers conducted 331 nuclear bomb tests in the atmosphere, assuming all the while that the potent radioactive elements Strontium-90 and Cesium-37 had no pathway to enter the bodies of humans. These scientists knew that strontium-90, in particular, mimics calcium and can settle in the bones -- but they reasoned that cow bone fragments made up such a small fraction of typical hamburger meat that the hazard to average Americans was negligible. It simply escaped their notice that calcium-rich cow's milk, contaminated with stronium-90, was routinely being fed to almost all U.S. children in large quantities. Eventually a survey of children's baby teeth, by independent scientists, revealed that radioactivity was building up in children, and above-ground nuclear tests were banned. (Barry Commoner documented this astonishing lapse in his early book, Science and Survival.)

History reminds us that we have good reason to be exceedingly skeptical of technical elites who assure us that the monstrous gamble they are pressing us to take is "perfectly safe" (as the Natural Resources Defense Council [NRDC] likes to call it) for our children and for our children's children, and for their children... for the next 5000 years.

6. Successful perpetual storage can never be demonstrated

Given that the goal is perpetual storage of CO2, no experimental burial program can provide proof of success. On whatever day "success" is proclaimed, leakage could always occur the next day.

The plan is to compress CO2 into a liquid and then pump it a mile or so into the deep earth through boreholes or wells drilled for the purpose. Researchers at Lawrence Berkeley National Laboratory surveyed some known instances of natural and industrial releases of CO2 from underground storage reservoirs and published their results in 2007. They concluded that, "Wells that are improperly constructed or abandoned, and have become structurally unsound over time, have the potential to rapidly release large quantities of CO2 into the atmosphere."[6] How will anyone know when a particular well is becoming structurally unsound as time passes -- until leakage is detected (which assumes someone is monitoring and paying careful attention).

It is simply not possible to make a short-term "demonstration" of successful perpetual storage of CO2 in the ground. Any such program can legitimately demonstrate "failure" (if leakage is detected), or it can be legitimately labeled "inconclusive" so long as no failure has been detected. But it can never be legitimately labeled "successful" because it could always start leaking the day after "success" is declared. (Recall the anecdote of the man who jumped off the skyscraper and declaimed, as he fell past the 20th floor, "So far so good.")

7. CO2 underground may move in ways that are poorly understood

Liquified CO2 will be pumped under pressure a mile or more underground, in many instances intentionally injecting it into water- bearing strata of rock where it will form carbonic acid with a pH as low as 3, which can leach rock and metals. The CO2 will also be buoyant, tending to rise back toward the surface of the earth. It will also be under great pressure, tending to squirt wherever it finds a suitable pathway. For these reasons, it will have a tendency to move. Once CO2 is buried, its whereabouts will never be precisely known unless the site has been thoroughly characterized beforehand. Because of this, it will not be entirely clear where to monitor for leakage.

Although the petroleum industry has developed some remote sensing techniques, they are not 100% reliable. Detail is missing. The only way to be sure about the nature of an underground site is to bore into it repeatedly and examine samples. Unfortunately, every borehole creates a new pathway for eventual leakage, ruining the natural integrity of the site. It's a catch-22: you can have a well- characterized site that has lost its natural integrity, or you can have a site that retains its integrity but is not fully understood. Either way, the fateful decision to pump billions or trillions of tonnes of acid-forming, pressurized liquid CO2 into the deep earth will remain a monstrous gamble.

8. Humans may inadvertently disrupt underground CO2 sites

Future generations will face resource shortages of the kind we ourselves are now experiencing, only theirs will very likely grow more acute as mineral deposits, fossil fuels, and water supplies become ever scarcer. Future generations will no doubt explore the subsurface of the earth looking for useful minerals -- leftover metals, potash, coal, oil, natural gas and perhaps water, as we ourselves have done with great diligence for the past 110 years. How will we warn future humans against drilling into the thousands of CO2 storage sites we are planning to create, potentially releasing large quantities of global- warming gases?

9. Humans have no experience monitoring dangers in perpetuity

After large quantities of CO2 have been buried, humans will need to monitor each site in perpetuity -- again, something humans have no experience doing. Even if we define perpetuity the way it was defined for the Futuregen project -- a mere 5000 years -- that's still 200 generations of humans.[7] How does one generation reliably pass along to 200 subsequent generations the knowledge of what hazardous waste was buried where?

Over a 5000 year period, civilizations will come and go. Technologies will change drastically, including record-keeping technologies. (Many computerized storage devices in common use just 20 years ago are no longer readable by contemporary machines.) Natural catastrophes (earthquakes, fires, floods, tornadoes, etc.) occur regularly, as do wars, revolutions, mass migrations, and political and social turmoil of various kinds and degrees. During all such events, buildings can be destroyed, people displaced, bureaucratic hierarchies destabiliized, social and political order compromised, old priorities and problems displaced by more pressing new ones -- resulting in records lost, discarded, abandoned, or destroyed. How can we assure that future humans will know of the dangers we have left buried for them to manage at thousands of sites across the globe?

This raises a related question: why did the U.S. Department of Energy's Futuregen "clean coal" CCS project in Illinois (now canceled) limit its time-horizon to only 5000 years? After all, the Yucca Mountain radioactive waste project proposed by the same U.S. Department of Energy has set its safety time-horizon at one million years. At Yucca Mountain, the goal is to build a geologic barrier that has an excellent chance of not releasing radioactivity for a million years. Why should a CO2 storage program be held to a lesser standard -- especially since large amounts of CO2 are arguably a greater hazard to the future of the planet than modest amounts of radioactive waste?

10. How will humans remain alert for thousands of years?

A separate though related problem is how to assure that future generations will take their monitoring responsibilities seriously for the duration of the hazard. As time passes and nothing happens, humans tend to lose interest in a problem and turn their attention and resources elsewhere. This seems natural. In truth, any plan for perpetual storage and monitoring of CO2 runs counter to everything experience tells us about humans as vigilant, competent managers. If a site is monitored for, say, 200 years with no leakage detected, how will humans be persuaded to remain vigilant, perpetually maintaining a complex monitoring system?

The subsurface of the earth -- particularly a subsurface that has had millions of tons of corrosive, pressurized liquid pumped into it -- will not necessarily remain static. Who can say that a leak will not develop in year 201, or in year 4001? Constant vigilance will be essential, but such vigilance runs counter to human nature. How can these conflicting realities be satisfactorily resolved to protect the future against the great hazards we are creating for them?

11. Leakage through fractures or faults cannot be sealed off

If leakage occurs, even if it is detected, how can it be stopped? If the leakage is occurring through a borehole AND it is detected, plugging the leak seems possible. But what if the leakage occurs through a geologic fracture or fault that was not initially detected? How does one seal an underground fracture or fault?

Can we avoid siting CO2 storage sites near fractures or faults? We would do well to recall the Japanese nuclear reactors, which, we discovered in 2007, were built on undetected geologic faults that in fact gave rise to earthquakes, which damaged the reactors, spilling radioactivity. Japan is one of the most technically sophisticated nations in the world, yet they could not manage to avoid these egregious engineering errors.

12. Future civilizations may not have the capabilities we have

What assumptions do we have a right to make about the nature of future human societies? Will the future always be like the present? Will present-day institutions survive, or is it conceivable that the future will take on some of the features depicted in dystopias like "Mad Max," "Blade Runner," and "Escape from New York"? Could social chaos engulf the planet as resources dwindle? In sum, what are the prudent (and ethical) assumptions for us to make about the political, technical, and social capabilities of future civilizations?

13. The people engaged in CCS projects have a dubious history

Do the coal and power industries have a respectable record of compliance with mining laws, with mine reclamation laws, with health and safety regulations, and with environmental regulations? If we look at communities that have been dominated by these industries, what sorts of communities do we find them to be? After the mines peter out and the corporations move on, what sort of legacy do they leave behind? There is a historical record here that can be examined to tell us what sorts of people we will be dealing with in the CO2 burial industry. Can they be trusted? If you were intending to choose a group of people to protect the future of the human race, are these the people you would elect?

And what of the regulatory agencies themselves, charged with oversight of exploration for minerals, oil, and gas, and in charge of mining enforcement? Are they model agencies, or are have they shown themselves to be corrupt, venal, deceitful and ineffective? Do they aggressively protect the public interest, or do they tend to protect the industry they are charged with regulating? This, too, is a question that can be answered with empirical evidence from the historical record. Are these the people we want to designate as guardians of our future?

Here is some of the history for all to read:

Jeff Goodell, Big Coal: The Dirty Secret Behind America's Energy Future (Houghton Mifflin, 2006)

Barbara Freese, Coal: A Human History (Penguin, 2004)

Erik Reese, Lost Mountain: A Year in the Vanishing Wilderness (Riverhead Books, 2006)

K. Ross Toole, The Rape of the Great Plains: Northwestern America, Cattle and Coal (Little Brown and Company, 1976)

14. So far, no one is arranging for the polluter to pay

The United States is committed to the principle that the polluter should pay, which is fair and entirely consistent with free market ideology. Yet the coal and electic utilities are urging that they retain legal liability for their hazardous waste CO2 burial sites for only 10 years. After that, they want the public to accept legal liability for whatever damage their projects may cause in the future. If these corporate executives have so much confidence that their hazardous waste burial sites will remain safe for at least 5000 years, why are they unwilling to retain liability for the duration?

Given that these corporations are trying to evade liability for their actions, we could invoke an excellent solution first proposed by economist Robert Costanza -- a performance bond. Performance bonds are common today for construction projects. Here's how it works: Government develops a worst-case scenario[8] for a CO2 burial project, and calculates reasonable costs; the CO2 burial firms then post a performance bond large enough to cover the worst-case costs. The government holds the bond until the end of the project (whether it be 5000 years in the future or a million years in the future, or somewhere in between) at which time the corporations get their performance bond back with interest (assuming no problems have occurred). In the meantime, the bond fund is available to pay for long-term monitoring, maintenance, remediation, and, if needed, compensation for damages. If the CO2 burial industry and its financial backers have confidence in CCS technologies, they should willingly post such a performance bond, which is now common practice for construction projects. If they are unwilling to post such a bond, we should take it as a clear sign that they lack confidence in their own CCS Plan and are knowingly engaged in a monstrous gamble with the future of the planet.

15. Dangerous CO2 burial raises environmental justice concerns

CO2 burial does entail some serious risks of acute harm. CO2 is heavier than air and when the rare large CO2 release occurs, oxygen can be excluded from large areas, killing all living things for many miles around.[6] Therefore, as with all hazardous waste facilities, siting has the potential to create environmental injustices. For example, the Sasol Corporation in South Africa has proposed to bury CO2 in neighboring Botswana -- but the people of Botswana are wondering, why they have been chosen as a dump for hazardous waste CO2?[9] No environmental justice standards and regulations been developed to deal with the host of unique new problems posed by capture, transport and burial of pressurized liquid CO2. Coal companies have not acknowledged the potential for environmental injustices and, in concert with environmental justice advocates, developed a plan to avoid further harm to communities that are already burdened or vulnerable.

16. Large centralized energy plants threaten national security

Coal power plants, like nuclear plants, are large and highly- centralized and therefore subject to major disruptions. When something goes wrong at one of these plants, a cascade effect can turn off the lights for tens of millions of people, as happened in the U.S. in 1965, 1977, and 2003. In the present day, large centralized power plants pose a serious threat to national security. A modern "smart grid" linking many small, renewable power sources can be made much more robust, far less subject to interruption, whether mischievous or accidental. A robust, distributed electrical grid is essential for the sustainability of our civilization. This requires us to eliminate large coal and nuclear power plants. (See Amory and Hunter Lovins, Brittle Power (1982).)

17. Large centralized energy plants undermine democracy

A decentralized national power system is suited to community-level control, which is is appropriate for a nation that prides itself on its commitment to democracy. Very large centralized power plants (and power companies) -- whether coal or nuclear -- are inconsistent with (and corrosive of) our democratic principles. Municipal-scale (or smaller) power generation is consistent with democracy and best for national security. (It is worth noting that E. F. Schumacher, author of the 1973 collection of essays, Small is Beautiful, developed his ideas during his 20 years as chief economic advisor to the National Coal Board in the U.K.)

18. CCS is a waste of both money and energy

CCS is a waste of both money and energy. CCS will increase the power needs of a typical coal plant by 10% to 40% -- meaning that 10% to 40% more coal must be mined, transported, and burned, producing 10% to 40% more wastes that must be managed. The destructive effects of coal mining are legion. Mine wastes present enormous long-term problems for current and future generations, and these costs are typically "externalized" -- meaning passed along to the public and to our children. Is this fair, especially given that it is unnecessary?

19. CCS wastes water, doubling the water needs of coal plants

Coal gasification with carbon capture increases the water requirements of coal plants by 90% -- almost double. In a world already plagued by water shortages that are serious and growing, water can no longer be taken for granted. Water conservation and efficient use of water will be part of any truly sustainable civilization. Given that coal gasification with CCS wastes water, and gasification with CCS is not necessary, how can we justify investment in these wasteful technologies?

20. CCS must be heavily subsidized

The coal and electric power industries are unwilling to fully invest in these technologies, in which they claim to have complete faith. They say they need multi-billion-dollar federal subsidies, legal limits on liabilities, and guarantees on loans before they will be willing to proceed. (Illinois has already passed a law limiting the liability of the Futuregen "clean coal" project's industrial partners.)

What the CCS industry is really banking on is a "cap and trade" program whereby they can be paid for avoiding the discharge of CO2 into the atmosphere.

Given that there are alternatives for generating electricity that involve far smaller CO2 emissions, no coal combustion wastes, and far smaller amounts of mine waste, why should we pay the "clean coal" industry to burn coal and bury hazardous waste CO2 in the ground? We could invest those same funds in renewable energy and avoid the hazardous CO2 waste problem entirely.

* * *

This does not exhaust the list of problems that come to mind when the coal and electric power industries consider burying billions or trillions of tonnes of hazardous waste liquid CO2 a mile below ground all across the planet.

So "clean coal" faces us with a choice: we can bury enormous tonnages of dangerous waste CO2 underground all around the planet at great expense to maintain our commitment to 19th century technologies and political forms, and in the bargain saddle future generations with a perpetual threat and fear of catastrophic global warming. Or we can promote renewable energy across the globe -- solar, wind, tidal, and geothermal, spearheaded by a primary emphasis on energy conservation and efficiency -- thereby creating millions of green jobs and restoring America's economic, industrial, and ethical leadership.

Which path seems best to you?


[1] U.S. Environmental Protection Agency and U.S. Department of Energy, Coal Combustion Waste Management at Landfills and Surface Impoundments, 1994-2004 [DOE/PI-0004 ANL-EVS/06-4]] (Oak Ridge, Tennessee: U.S. Department of Energy, no date [2006?]. Table 21, pg. 43. Available at http://www.osti.gov/bridge.

[2] International Energy Agency, Near-term Opportunities for carbon Dioxide Capture and Storage; Global Assessments Workshop in Support of the G8 Plan of Action (Paris, France: International Energy Agency, 2007), pg. 7. Available at http://www.precaution.org/lib/iea_global_assessments_wkshop.070601.pdf

[3] According to Oak Ridge National Laboratory's Carbon Dioxide Information Analysis Center (CDIAC), global carbon emissions during the 20th century totaled 267 billion metric tonnes (267E9 tonnes); to convert carbon to carbon dioxide, multiply by 44/12. So 267E9*(44/12) = 979E9 tonnes of CO2 released during the 20th century. There are an estimated 3510 billon tonnes of carbon in remaining coal reserves, worldwide; if this were all burned it would yield 3510E9*(44/12) = 12.87 trillion (12.87E12) tonnes of CO2. So burning 80% of remaining coal would yield roughly 10 trillion tonnes of CO2, which is 10 times total 20th century CO2 emissions. The estimate of total global coal reserves is from P. Falkowski and others, "The Global Carbon Cycle: A Test of Our Knowledge of Earth as a System (Science, Vol. 290, Oct. 13, 2000, pg. 291-296).

[4] The apt phrase "monstrous gamble" to describe CCS originated with Robert M. Sargent of U.S. Public Interest Research Group.

[5] See, for example, "Whatever Happened to Deep Ocean Storage?" Environmental Health Perspectives Vol. 115, No. 11 (November 2007), pg. A545.

[6] Jennifer L. Lewicki, Jens Birkholzer, and Chin-Fu Tsang, "Natural and industrial analogues for leakage of CO2 from storage reservoirs: identification of features, events, and processes and lessons learned," Environmental Geology Vol. 52, No. 3 (April, 2007), pgs. 457-467.

[7] Anonymous. Final Risk Assessment Report for the Futuregen Project Environmental Impact Assessment (No place of publication: No publisher, October, 2007). (8 Mbytes PDF)

[8] The U.S. has ample experience conducting worst-case analyses because the President's Council on Environmental Quality required worst case analysis in its 1977 regulations governing the preparation of environmental impact statements. See Council on Environmental Quality, "Regulations for Implementing the Procedural Provisions of NEPA [National Environmental Policy Act]," reprinted as Appendix F in Council on Environmental Quality, Environmental Quality-1979 (Washington, D.C.: U.S. Government Printing Office, 1979), pgs. 760-794. The discussion of worst case analysis, as a way of dealing with uncertainty, is found in Section 1502.22. These regulations appeared in final form in the Federal Register Vol. 43 (1978), pg. 55987 and following pages. These regulations were revised during the Reagan presidency in 1986, removing the requirement for worst case analysis.

[9] "Botswana reluctant about Sasol CCS plant," Carbon Capture Journal Vol. 1 (Jan/Feb, 2008), pg. 27. [2 Mbytes PDF]