Document Y9GMO680jgwVOXn1bbMedB5Yk

USSOA02see##241-1280 Ciaoouratatit206636@3 FFfildc1006/2Y22024 PIgge453 of @28 19. Technological issues related to carbon capture arc not the only reason Colstrip would be unable to rely on the C:C:S pathway to comply with the Final Rule. Even if 90% of COE could be captured by 2032, it would need to be transported for storage and stored. Sequestration sites have not been adequately demonstrated in the vicinity of Colstrip and would require additional time, exploration, and significant cost to complete, in addition to the costs associated with transportation of the CO2. Colstrip, located in eastern Montana, is not near to any developed COE sequestration sites. It is not known whether the geological formations necessary for CO? sequestration exist in the vicinity of Colstrip, and additional drilling and exploration would be required to determine this. Further, no pipeline currently exists to carry captured CO2 from Colstrip to a storage location. 20. In fact, a study referenced in the proposed Rule reports that the costs of transportation and storage for the purposes of CC'S are much higher in Montana's Powder River Basin than in other states. CO-) pipeline transportation and storage cost in 2018 was $22/tonne for the Powder River Basin. The other basins in the study were Illinois (SIO/tonne), Fast Texas (S11/tonne) and Williston ($15/tonne). 21. On top of these prohibitive costs, there are a number of other challenges associated with evaluating, permitting, siting, designing, and constructing such a COE pipeline. Permits and easements would need to be acquired. It is unlikely such a pipeline could be constructed and operational prior to the compliance date required by the Final Rule. 7 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000309-00057 SC_EVERSPLIT0006220