First, natural gas-fired CO2 emissions are about 50% of the current generation of circulating fluidized bed coal-fired plants. This may not be true in the future as more coal plants utilize gasification processes.

Second, there is a reason natural gas-fired generation has low utilization today. While it is cheap to build, it is very expensive to operate. Natural gas-fired generation is a the top of the production cost model even with currently reasonable natural gas prices. There are several factors that will cause the cost of natural gas as fuel to go up. (1) If we use more natural gas-fired generation, that demand will drive natural gas prices up. We know this from experience. (2) As we bring more domestic shale gas into the fuel inventory, prices will go up because that extraction method is more expensive than what we have today. (3) As Europe, the Middle East, and other developing regions use more natural-gas fired generation, the cost of importing natural gas will increase. These cost drivers are just as fast-acting as starting up the natural gas-fired plants to replace coal-fired generation.

Third, if you increase the use of natural-gas fired generation in the US, then heating costs for businesses and residences will increase, and worst time being winter. In addition, we would see the return of 60%-70% annual price volatility in natural gas, which makes it very difficult for John Q Public to manage the costs at home.

Fourth, moving in a direction of using natural gas-fired generation to reduce CO2 emissions would give us a false sense of accomplishment. If you replaced all the coal generation, the US power generation CO2 emissions contribution drops from about 8% to 4%. Many people and groups would claim success with the resultant poliitics taking the heat off of truly solving emissions problems.

Fifth, if you take this study, some simple economic analysis, and some NETL studies about costs for next generation plants and carbon management, the result is a wash in relation to the delivered energy cost of using a \"clean coal\" fleet with carbon management and a natural gas-fired centric fleet with its sure to be higher costs of natural gas.

It is a shame that we have a trillion dollar natural gas-fired generation fleet operating at 10% - 30% capacity, but the cost of the fuel may preclude it from being a 75% capacity fleet today, and certainly tomorrow. I am not convinced that such a plan, or the Pickens Plan, gives us the best long-term strategy or even a bridging strategy.

This would require a more complete systems analysis to truly see if the nation would benefit from such a strategy, or if it would be just another quick and half-dirty dead end.

Steven Pullins