An environmental assessment published by the Department of Energy found that Project Tundra, a major coal carbon capture project proposed in North Dakota, would emit more greenhouse gases than it stores.

The environmental assessment also “includes numerous egregious errors” and “does not even meet the basic standards” for a life cycle assessment, according to Dr. Emily Grubert, former deputy assistant secretary of carbon management at the Department of Energy.

As the Department of Energy considers funding the coal carbon capture project, documents show that cost estimates for Project Tundra have nearly doubled, engineering studies have taken three times as long as initially planned, and emissions reductions claims have been scaled back.

Environmental assessment concludes Project Tundra will emit more carbon than it stores

The Department of Energy (DOE) published an environmental assessment of Project Tundra in August, as part of its obligation under the National Environmental Policy Act to analyze the potential impacts of funding the carbon capture project. DOE is proposing to provide half of the estimated $77 million to construct injection wells designed to sequester carbon dioxide captured from the Milton R. Young power plant, a 50-year lignite coal plant near Center, North Dakota.

Minnkota Power, the generation and transmission association that operates the coal plant, said in June that it has also applied for a $350 million grant from the DOE Carbon Capture Demonstration Projects Program to help fund the construction of the carbon capture facility. Project Tundra is unlikely to be built without DOE funding; in a presentation last year to the National Association of Regulatory Utility Commissioners, Project Tundra consultant David Greeson said that “we’re really counting on a demonstration grant from the Department of Energy.” The DOE environmental assessment also found that Project Tundra likely “would not be constructed” without federal funding.

The environmental assessment includes a life cycle analysis that determined that “There is an expected 3.23 kg of CO2e emitted per kg of CO2 stored.”

In an op-ed published in UtilityDive, Dr. Grubert noted “the analysis suggests that the project would emit more than three tonnes of CO2 equivalent per tonne of CO2 stored, and still recommends moving forward — a deeply alarming sign for a project whose entire purpose is to reduce GHG emissions.”

DOE did not provide a response to a question from EPI: Why is DOE proposing to fund a carbon capture project that it expects will emit more greenhouse gases than it sequesters?

Dr. Grubert also submitted a comment to DOE detailing some of the errors in the environmental assessment, and pointed to some of the most egregious errors in her op-ed:

The errors in the draft EA’s life cycle analysis of GHGs are numerous and often structural, but for illustration, the analysis overestimates one value by a factor of 23,500 without so much as a comment that the value seems unusually high. It also claims that the capture unit would require about three times as much coal-fired power as the power plant is capable of producing, but that this would not lead to any additional GHG emissions. These are basic competency errors that suggest either total inattention to this crucial analysis, or a startling lack of capability.

A spokesperson for DOE did not provide EPI with an explanation for the errors in the environmental assessment, stating only: “The Draft Environmental Assessment (EA) for the proposed North Dakota CarbonSAFE: Project Tundra is available for public comment until September 19, 2023.”

The life cycle analysis of Project Tundra in DOE’s environmental assessment was completed by Burns & McDonnell, according to an appendix.

Project Tundra engineering study took three times longer than expected

The DOE environmental assessment for Project Tundra says that “If approved, construction is anticipated to begin in 2024 and to be complete by 2028.” If Project Tundra is built and completed by 2028, that would mean it took about 12 years in total, since it was proposed in 2016 by North Dakota’s Senators and coal industry lobbyists.

Project Tundra has suffered several delays and missed deadlines for completing engineering studies and beginning construction. In 2020 and 2021, the Project Tundra website claimed: “Project Tundra is in the advanced research and design phase. If the project moves ahead, construction will commence in 2022-2023.”

Engineering and design studies for Project Tundra have taken far longer than originally planned, and quarterly reports with updates about the studies show higher than expected costs, and the departure of a key contractor. Minnkota Power submitted the quarterly reports to DOE, which provided a $9.8 million grant for the engineering studies; EPI obtained the reports through FOIA requests.

The DOE-funded engineering study was originally expected to take 15 months, from October 1, 2019 until December 31, 2020. But DOE extended the deadline to complete the engineering study six times, resulting in a 45-month timeline ending in June 2023.

DOE initially extended the deadline to complete the engineering study by six months in December 2020; it then provided another six-month extension in June 2021, a third six-month extension in Fall 2021, a fourth six-month extension in February 2022, a fifth six-month extension in June 2022, and a sixth six-month extension in January 2023.

A Government Accountability Office report in 2021 documented problems with DOE’s carbon capture program, including that “DOE’s process for selecting coal projects and negotiating funding agreements increased the risks that DOE would fund projects unlikely to succeed.” The GAO report specifically noted: “According to DOE documentation and officials, senior leadership directed actions to support projects even though they were not meeting required key milestones.”

Project Tundra counts at least one key senior DOE leader as a proponent; before he took a job leading the DOE office focused on carbon capture projects in 2022, Brad Crabtree promoted Project Tundra as , including in 2017 letters urging Congress and President Trump to fund eight specific carbon capture projects. When President Biden nominated Crabtree, the executive director of North Dakota’s coal industry lobbying group congratulated Crabtree, saying: “We consider it a unique opportunity to have a native son of North Dakota to be selected for your position as assistant secretary for fossil energy and carbon management.”

The GAO report webpage shows that the recommendations made by GAO to DOE remain open, meaning that “actions to satisfy the intent of the recommendation have not been taken or are being planned.”

Cost estimates for Project Tundra have nearly doubled

Along with those delays, the cost estimates to build Project Tundra appear to have nearly doubled over the last two years, from “approximately $1 billion” at the beginning of 2022, to $1.45 billion according to reporting in March 2022, and more recently to $1.94 billion, according to a March 2023 presentation to DOE. 

The last slide of that presentation to DOE notes: “Capital cost – $1.94 billion,” and two other slides also describe the estimated cost: “Total Project CAPEX – $1,938MM”

In 2019, Minnkota Power estimated that Project Tundra would “cost approximately $1 billion,” and that figure was included on the Project Tundra website in a “Project Tundra By The Numbers” section throughout 2020, 2021, and early 2022.

Image from the archived website for Project Tundra, a proposed coal carbon capture project
Image from Project Tundra website, archived December 5, 2020

But in March 2022, The Forum of Fargo-Moorhead reported that Project Tundra’s cost estimates had increased to $1.45 billion. The Forum reported that higher cost estimate based on a document showing projects that had requested loans or grants from the North Dakota Industrial Commission. Minnkota Power submitted an application for a $150 million loan from the Industrial Commission on March 1, 2022, which also stated: “Total Amount of Proposed Project: $1,450,000,000.”

Minnkota Power continued to claim on its website that the project would cost $1 billion, until July 2022, when the “Project Tundra By The Numbers” section was changed to show a $1.4 billion cost.

Image from the archived website for Project Tundra, a proposed coal carbon capture project
Image from Project Tundra website, archived July 20, 2022

Today, the “Project Tundra By The Numbers” section still claims a $1.4 billion cost estimate, despite the $1.9 billion cost estimate shown in the March 2023 presentation to DOE.

Image from the website for Project Tundra, a proposed coal carbon capture project
Image from Project Tundra website, September 2023

Project Tundra aims to capture 74% of coal plant’s carbon emissions

The changes to the “Project Tundra By The Numbers” also show the removal of claims of a “95% CO2 reduction.” That was changed to “90% capture rate,” which was then changed to “4 million metric tons of CO2 captured annually.”

Minnkota Power is actually aiming for a 74% reduction of carbon dioxide emissions from the Milton R. Young coal plant, according to recent comments from a Minnkota representative. That figure also doesn’t account for upstream emissions, such as from increased coal mining to provide steam and power for the carbon capture facility.

During a hearing at the Minnesota Public Utilities Commission (PUC) last month, Commissioner Joseph Sullivan asked Minnkota Power staff: “Are you intending in the long run to capture 95% or 100% of the emissions from the unit?”

Minnkota Power attorney Shannon Mikula explained how Project Tundra is designed to be able to capture emissions from both units of the coal plant, but did not directly answer Sullivan’s question.

Sullivan then asked: “The long term goal, there will still be some emissions from the entire facility, it would just be significantly less than emissions today?”

“So as station on a whole basis, it’s about 74% reduction of CO2 off the baseline, is what the design indicates,” Mikula responded.

In earlier filings submitted to the Minnesota PUC, Minnkota Power claimed that “Project Tundra can result in ~300 MW net of near “zero carbon” power for sale to our members.”

Minnkota Power said in July that it “anticipates making a decision on whether to move forward with construction of Project Tundra in early 2024.”

Posted by Joe Smyth

Joe Smyth is a Research and Communications Manager for the Energy and Policy Institute.