Comment Log Display

Here is the comment you selected to display.

Comment 383 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameEdward
Last NameBergen
AffiliationSan Diego 350
SubjectCarbon Capture and Storage

I am a former R&D construction project manager and volunteer for San Diego 350.  I advise against the inclusion of carbon capture and storage (CCS) in the proposed plan for reducing greenhouse gases in the atmosphere.  I developed expertise in a proven technology that excels in the bulk removal of carbon dioxide (CO2) from industrial gas streams.[i]  The atmosphere contains a lot of carbon dioxide; however, it is present at only 421 ppm concentration and one atmosphere pressure.  Practical bulk removal of CO2 requires much more elevated concentrations and pressures.     

 Last year, a record 36.3 billion tons of CO2, a byproduct of burning fossil fuels, were released into the global atmosphere.[ii]  One CSS technology touted as a solution is direct carbon capture (DCC).  Orca, a new 4 thousand ton per year DCC plant powered by geothermal energy is operated in Iceland by Climworks.[iii]  The Orca facility has produced a lot of buzz for DCC, however DCC is not suitable for bulk removal of CO2 from the atmosphere.  Once CO2 is released into the atmosphere, CO2 will stay until removed by photosynthesis.  Let’s compare the daily worldwide CO2 release and DCC removal figures:

·        36.3 billion tons released per year is about 100 million tons per day.[iv]

·        4 thousand tons per year removed by Orca is about 11 tons per day.

·        A massive fleet of DCC plants (9 million the size of the Orca demonstration plant) would have to be scaled up and built to remove 100 million tons per day, the CO2 emissions of just the past year. 

·        DCC cannot be scaled up to significantly offset global CO2 emissions.  DCC is an inherently inefficient technology that funds operations by selling carbon offsets to prosperous clients.  Atmospheric CO2 is not suitable for bulk removal.

It is easier to collect CO2 from concentrated sources with existing technology than capture CO2 directly from the air through DCC.  It is far easier if the CO2 is available at higher pressures than the atmospheric pressure of direct capture methods or flue gases released from burning fossil fuels.  The Schute Creek plant in Wyoming has the capacity to capture 7 million tons per year for underground injection.[v]  This scheme has increased the amount of CO2 released into the atmosphere, by:

·        Direct venting of unused CO2, about half of the total captured in 35 years.

·        25% more energy is required to run the CO2 recovery equipment and injection compressors.[vi]  CO2 from burning the fuel needed to produce this energy required is directly vented to the atmosphere.

·        More energy and resulting CO2 venting is needed to manufacture the added equipment needed for CO2 capture and compression.

·        The oil produced by CO2 motivated enhanced oil recovery is burned and releases more CO2.

While compression of CO2 for injection was expensive, it was justified by the value of oil recovered.  When the value of recovered oil decreased, compressors were shut down.  

 Carbon Capture and Storage is an inefficient and expensive diversion from our task of reducing the amount of CO2 released into the atmosphere.  CCS would keep the multi- trillion-dollar fossil fuel industry consuming time and financial resources California needs to scale up renewable energy and replace fossil fuel energy. 

We residents of San Diego pay the highest electrical rates in the continental United States.  The electrical rate from my bill last month was over 30 cents per kilowatt hour!  One quarter of San Diego ratepayers are behind on their utility bills. [vii]

We remember the $4.7 billion cost of the San Onofre Nuclear plant equipment failure. We don’t want to pay for inherently inefficient technology that only serves to delay halting fossil fuel consumption and carbon pollution.  We don’t want to forever lose San Diego’s mild climate because of misplaced enthusiasm for DCC and underground CO2 storage.  Why burn fossil fuels?  As carbon pollution increases, nighttime cooling slows, and deadly heat waves can linger.   

Contrast these dim prospects using an expensive 20th century approach, with the rapidly falling price of electricity produced by photovoltaic generation in the 21st century.  The cost of photovoltaic generation has dropped 90% since 2010 to 10 cents per kilowatt hour.  It is proven, economical technology operating today at scale. 

Ask any Californian how she would like to stop burning fossil fuels, breathe healthy, clean air and purchase power at 10 cents per kilowatt hour!  Photovoltaic power is a much better investment than CSS.  We no longer fly the Hindenburg, why burn fossil fuels?

[i] [i]I was elected a Fellow of the American Institute of Chemical Engineers in 2009 based partly on my work in developing scrubbing solutions for the Benfield bulk acid gas removal process.


[ii] International Energy Agency, “Global Energy Review:CO2 Emissions in 2021,” available online at   (accessed 6/13/2022)


[iii] Giving, “Climeworks,” available online at  (accessed 6/13/2022)


[iv] (36.4 billion tons/year) * (1 year/365 days) = 100 million tons/day

   (4000 tons/year) * (1 year/365 days) = 11 tons/day


[v] Institute for Energy Economics and Financial Analysis, “IEEFA: Shute Creek – world’s largest carbon capture facility sells CO2 for oil production, but vents unsold,” available online at  (accessed 6/13/2022)


[vi] Cheddar news, “White House: Carbon Capture Key to Fighting Climate Change,” Interview with Mark Jacobson, Professor of Civil and Environmental Engineering at Stanford University, Available online at  (accessed 6/13/2022)


[vii] Kpbs, “More than 25% of SDG&E residential customers’ utility bills are overdue,” available at  (accessed 6/13/2022)



Original File Name
Date and Time Comment Was Submitted 2022-06-21 17:52:08

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

Board Comments Home