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India ranks second in global hard coal reserves and is amongst the largest coal users worldwide. 70% of indigenous coal production goes on electricity generation, coal accounting for 2/3 of fuel inputs to the Indian power sector. Coal output has been rising at a steady rate of about 4% per year since 1990. The development of proven reserves has followed the growth in extraction. The coal R/P ratio has declined only marginally and still exceeds 200 years, well above the world average. About 75% of coal comes from open-cut mines. The factors that may adversely affect the security of coal supplies in India are the following:

Most Indian coal is of poor quality because of the rather high content of ash (30-50%) and water (4-7%) and consequently a low calorific value (13-21 MJ/kg). When such coal is directly employed in power generation, the resulting electrical efficiencies are low. Alternatively, coal can be pre-treated (washed), but this adds to the costs and results in an 8-15% energy loss. Although the gross R/P ratio is high, the amount of realistically exploitable reserves is uncertain. At present, most Indian coal is mined at depths of 150-300 metres. The deposits at such depths may be sufficient for 50-60 years only. The recovery of deeper reserves may be precluded by excessively high costs. Most coalmines are state-owned, a fact that constrains private investment in the sector. Investment in coal supply is particularly impeded by distribution regulations and control over foreign investment. The operation of coalmines is outdated and productivity is very low compared to international standards, especially in underground mining. Most coal deposits are located in the northeast part of the country, while the major consumption centres are in the west and southwest (including coastal) areas of the country. Bringing coal to the major consumers, especially in unwashed form, involves expensive transport by rail over large distances (500-750 km). Transport costs may account for up to 70% of total delivery costs. For a number of reasons, including the presence of three different gauges, the condition of the Indian railways is far from perfect. Improving the railways calls for huge investment, this does not seem

realistic in the foreseeable future. For these reasons, and also to improve average coal quality, many power plant operators in the west and southwest parts of India are importing increasing volumes of higher-quality steam coal. The power generation sector is heavily regulated and electricity prices are kept at very low levels that basically preclude investment. Power plant operators have little incentive to invest in improving coal quality, the development of logistical infrastructure or the modernization of power plants. Most power plants are over-aged, outdated and consequently inefficient. The current 10% share held by imports in Indias total coal supply may increase in the future, driven by several factors. Electricity demand is set to expand along with the fast-growing economy. Another aspect driving electricity demand is the low electrification rate especially in rural areas, where the grid connection level is only 30%. Increasing the share of imports may be the preferred option, not only because of the poor quality of indigenous production but also because surface mining, which is suitable for the majority of indigenous coal reserves, requires the relocation of population and activities. Such relocation might pose challenges in view of the countrys high population density. On the other hand, imports may be impeded by the generally poor state of port infrastructure and the resulting port congestion and vessel delays, on top of the usual heavy delays during the monsoon season. All in all, however, considering the size of the country, even a modest increase in imports will most likely give very strong signals to the regional and world coal markets.

It is true that historically coal has been cheaper than oil and gas on an energy content basis. This may change, however, not only due to the higher cost of coal application technologies compared with natural gas (coals main rival on the electricity market), but also because the following factors behind the lower price for coal may no longer be present in the future:

Lower attractiveness (for environmental reasons) of coal compared to nuclear power and especially natural gas for electricity generation in industrialized countries. Nonetheless, energy demand in developing countries and emerging economies is rising faster than in industrialized countries. By definition, low costs are of higher priority than a clean

environment for less developed countries. The fact that the largest energy consumers amongst these countries have bigger reserves of coal than of oil and gas will give an additional impetus to coal demand and prices.

Low concentration of supplies with a relatively large number of market actors. However, the emergence of an OPEC-like cartel for coal seems little probable in the foreseeable future. Its creation would also be difficult because the coal industry is much smaller and has far less economic power than the oil and gas industries. The regional and country overview has revealed that coal recovery in most countries will incur higher production costs in future. Since international coal prices are still linked to production costs, an increase in the global price levels of coal can be expected. On the other hand, any enhancement of world coal reserves may be hampered by the poor return on investment in coal mining over the past few decades. The low profitability has been due to the strong price competition in the world market and correspondingly low coal prices. Although the investment needed to secure adequate reserves of coal by 2030 is estimated to be only 3% of all necessary investment in the energy sector by 2030 (compared, for instance, to 19% for gas), the lack of a sufficient and stable cash flow may impede a timely commitment. Consequently, the coal supply base may be further squeezed and the pressure on coal prices reinforced by such pessimistic expectations. This phenomenon can be termed the psychological depletion of proven reserves, which always comes before physical depletion. Research and development (R&D) spending on coal mining has been steadily declining over the past 20 years., the future world oil, gas and coal markets will most likely become increasingly inter-related and the energy market will tend to develop into a global market of hydrocarbons.

Consequently, the relative gap between coal prices and oil and gas prices will most likely narrow. This will be more pronounced for higher-quality coals, and a wider differentiation in coal prices, depending on quality specifications, may be expected. The demand for energy can be drastically reduced if energy efficiency across all sectors improves. Since electricity generation is the prime consumer of coal, raising efficiency in this sector could shrink coal demand. However,

efficiency improvements may be impeded or delayed, and the actual reduction in coal demand may be smaller than initially expected, because of the following reasons:

The volatile return on investment and poor profitability were indeed the key reasons for the big oil companies to leave the coal business in the late 1990s. Efficiency can be increased either by upgrading existing power plants or by replacing old electricity generation facilities with new facilities. However, both options need significant additional investment that can be recouped only over a relatively long period of time. Recent estimates suggest that plenty of oil and gas could become available if the long-term oil price stays above USD 30 per barrel. Such a level does not appear high enough to boost large-scale investment in more energy-efficient technologies, in particular for power generation. Tougher environmental standards for the operation of power plants require the installation of additional and expensive flue-gas cleaning facilities. All these facilities consume energy.

Generation Capacity based on Feedstock

The generation capacity in India comprises of a mix of thermal, hydro, nuclear, and renewable energy. Over the years thermal energy has become a dominant source of power generation. As of Jan 2010, thermal energy contributed 64% (100,351.5 MW) of the countrys total power generating capacity, while hydro energy contributed 24% (36,885.40 MW), renewable energy sources around 9.8% (15,427.10 MW), and nuclear energy contributed 3% (4,120 MW) to the total capacity. Thermal fuel maintains a leading position among the fuel used for power generation. In spite of efforts to reduce the countrys dependence on thermal base generation, the cost (relatively higher for other sources of generation) or the unavailability of other sources of energy have remained a constraint. During the Tenth 5-year Plan, the planned capacity addition had a greater focus on the thermal generation space and the same trend has been continuing during the Eleventh 5-year Plan. Most of the power generation capacity will continue to be thermal as most upcoming projects are coalbased.

Hydropower is an environment-friendly alternative for thermal power generation and the operating cost for running a hydro plant is also very low; however, its share in generation has remained constant and has not attracted much investment. The hydro-thermal mix has maintained a leading position over the years, but the share of hydropower plants in total generation has fallen over the years. In the mideighties, the share of hydropower in total generation was comparable to that of thermal generation, but, since then, investments in hydropower generation have risen at a lower rate than investments in thermal generation. Though the operating cost for hydropower plants is lesser, the capital investment required in the initial stage is huge. Investors have shied away from the sector because of delays in environment clearances that have made the sector an unfavourable choice and have restricted capacity addition in the sector. Thermal energy, on the other hand, has gained a greater share over the 5-year plan periods and its growth rate has also been much higher, as investments from public as well as private sectors have continued to pour in. In the Eleventh Plan also capacity addition focuses more on thermal power generation, which suggests that thermal energy will remain the dominant source in the coming years. Nuclear energy has had a very small share in the power generation pie, but its share in total power generation was expected to rise post the Indo-US Nuclear Civilian Agreement. India has only one nuclear power generation company, NPCIL, with a capacity of 4,120 MW, but due to recent developments many private and public sector utilities had envisaged plans for setting up nuclear plants. NTPC, Tata Power, GMR, Reliance Infrastructure, and GVK are some such companies. But the recent Japan Nuclear incident, The renewable sources of power generation include wind power, small hydro power, biomass power, Urban & Industrial (U&I) waste to power, solar power etc. Among these sources, wind power has a leading share of 70% in the RES, while small hydro has 7%, cogeneration-bagasse 7%, biomass 5% and solar & waste to energy constitute less than 1%.

In FY10, about 92% of the coal produced by CIL was non-coking coal which is primarily consumed by the power sector. The remaining 8% is coking coal which is primarily consumed by the steel sector. In FY10, CIL supplied 80% of its coal to the power sector.

Indias annual coal demand to grow by 1.2bn tons by FY20: 120mn tons/year of coal demand added every year; this is on power and steel capacity additions considered conservative by many Coal India to add only 30mn tons/year of new supply

Captive mining and imports thus need to add ~800mn tons of supply in 10 years; Captive mining can only add ~350mn tons Thus India would need to import ~500mn tpa by FY20: there is not enough port capacity or infrastructure to move coal from ports/mines to power plants which are located inland There should be a meaningful policy response, but likely not in time

Hefty discount (62-63%) of CILs notified prices of coal to global coal prices unsustainable; discount likely to narrow over the next decade The pricing strategy of CIL until now has been limited to covering rise in production costs which have not been offset by productivity and efficiency improvements. As a result, hike in CIL's pricing has been lower than inflation rates and significantly lower than global coal prices which have soared. CIL sells about ~83-84% of its coal through long term agreements with its customers called Fuel Supply Agreements (FSA) under the notified pricing system, out of which ~93% is at a significant discount to global coal prices. Through the construction of an index comparing the change in price movement of global thermal coal contract prices and CILs notified prices, taking FY05 as the base year, we estimate that CILs notified prices are at a ~62-63% discount to global thermal coal contract prices (Refer Chart-9). While global thermal coal contract prices have risen 2.25x from $40 per tonne in FY05 to ~130 per tonne in FY12E, CILs notified prices have been increased only twice by a total 22.1% post the June 2004 price increase.

Natural Gas - Current Pricing Mechanism in India

Limited availability of domestic coal and gas is constraining development of Indian power sector, which is expected to see on average an annual capacity addition of 12,000 MW over next five years.

Even with easier equipment procurement and increasingly streamlined approvals, Indian power sector development is being held back by limited availability of domestically sourced coal and gas. Shortage of coal is affecting the country's power sector, whose main source of generation is thermal power plants. The shortage of coal is likely to reach 137 MT this fiscal and 200 MT by FY17. Growth is constrained by the ability of power purchasers to afford higher power prices that will result from an increasing reliance on imported fuel, which is much more expensive. India is expected to add 45,000 MW of coal-fired generation capacity between FY10 and FY15. The Indian power generation capacity is expected to see a Compound Annual Growth Rate of 6.5% over the next five years, or an average of 12,000 MW annually. Of this, we expect coal-fired capacity to account about 67% of the total, wind 12% and gas 8%. In the current five-year plan (2007-12), the Power Ministry is expected to see a capacity addition of about 51,000 MW. The capacity addition in the first four years of the 11th Plan ending March 31, 2012, stood at 34,462 MW. The government is targeting a power capacity addition of 1,00,000 MW in the 12th five-year plan (2012-17). Power plant investment would be constrained even if bureaucratic impediments to power plant development continue to fall because we think fuel availability, fuel costs and ability for off takers to absorb higher fuel prices will remain as significant challenges.

Pricing in the Power Sector

The majority of installed capacity in power is state-owned, and power is provided at heavily subsidized prices to specific consumer segments. Initial attempts at reform had mixed outcomes, and the lack of capacity addition between the mid-1990s and mid-2000s has led to massive peak and overall energy deficits. On a PPP basis, Indian energy prices, particularly for industry, are some the highest in the world (Report of the Expert Committee on Integrated Energy Policy, Planning Commission, 2006). Much debate exists over the distortions created by this, and it has been only recently, under the provisions of the Electricity Act 2003, and policy directives that have followed, such as the National Tariff Policy and National Grid Plan, that extensive reforms have been initiated towards correcting these distortions and creating competition. Reform measures that relate to generation are directly relevant to gas pricing.

Power Sector Reforms

The viability of gas in the power sector depends largely upon its cost competitiveness compared to coal, which in turn is closely related to the process of power sector reforms. About two-thirds of supply to gas-based power plants is at subsidized rates, through APM gas. Third party access will facilitate the harnessing of electricity produced from merchant and captive power plants, which have been projected as future growth areas for gas demand. According to the Electricity Act 2003, a generator has three options through which to sell power; first, to distribution companies by winning bids based on prices; second, by selling directly to a customer or to a distribution licensee for short term sales using open access regulations; and third, to an electricity trader. Captive power plants can sell surplus electricity using the first two options. Reforms also include the addition to generation capacity through Ultra Mega Power Plants (plants with an installed capacity greater than 4000 MW. There are currently 14 of these under construction or being planned (on a BuildOwn-Operate basis) in nine states. An important aspect of these plants is fuel linkage. From January 2011 onwards, under the National Tariff Policy, bidding will form the basis of power purchase by distributors, and public and private generators will have to compete. Due to the fact that no gas allocation has been made from the D-6 fields to new, Greenfield, power plants, bids have so far been made by distributors only for coal-based capacity. Gas faces significant price competition from coal. As 90 per cent of coal production is subsidized, electricity produced from coal is cheaper than from gas. Also, as coal mines are completely state-owned, fuel linkages for domestic coal are easily provided to both public and private generation companies through government policy. Domestic gas, however, lies increasingly in the private sector, and currently the only method of linkage to gas is through the gas utilization policy. The above brings out the extent of distortions in pricing in the power sector; in order for there to be a level playing field, there would either have to be equivalent linkages provided for gas-based capacity, or, there would have to be reforms in the coal sector.

In the short term, the only conclusion that can be made is that it will be difficult for gas to compete with coal for base load generation. This highlights the issues which have to be faced in the coal sector; any integrated policy on energy will have to take into account the fact that most fuel options will be unable to compete with coal at its current level of prices and policy. It can be argued that opportunities for the growth of gas-fired generation in the energy sector exist due to the energy deficit, which is likely to persist in the short term. However, the underlying assumption here is that, under the present system, the demand for gas is based mainly on failures in the generation sector, which may not be inevitable, and the first-best here would be to reform the generation sector per se. The viability of gas in power generation will therefore depend to a great extent on its cost competitiveness compared with other fuels, especially coal.

Gas Price Differentiation in Indian Market (2010)

(Source: IEA, Indian Oil and Gas, Industry announcement and presentations)
The Competitiveness of Gas-Based Power As gas-based power is likely to be more expensive than coal-based power, it will be viable only in specific segments of the power market. One such niche segment is the captive and merchant power sector. Another segment is power that is traded across states, using trading platforms operated by power exchanges. There are two exchanges in India, in operation since 2007, and the total volume of electricity traded in 2007 was roughly 3 per cent of total generation from utilities, although this is likely to increase.

Although most tradable power will be produced by merchant plants, the Ultra Mega Power Plants are also permitted to trade part of their generation. This could help the price competitiveness of gas- based power, as the higher generation costs could be passed on to the tradable component. Merchant power plants that have surplus power can make profits by selling this surplus to meet peak demand, as power supplied under this category is not under long term contracts. It has been suggested that several merchant power plants are being set up purely on the feasibility of a small share of their capacity being sold commercially at high prices through the power exchanges.

Major Issues: Regulation/Policy and Pricing.

The issues regarding policy are probably the most important: India needs a clear policy and regulatory framework in order to attract the investments needed in the energy sector, not only to sustain a high economic growth, but also to deal with poverty which leaves millions of people without access to energy. The role and powers of the regulators have to be clearly defined. India has opened up to private and foreign companies and these want regulatory stability with minimum intervention from the state. The government has reduced the gap between very cheap APM gas and more expensive other supplies. The dual system had indeed proven its shortcomings, which were increasingly visible as APM gas volume and share in total supplies diminished. Keeping low energy prices was not only a disincentive for upstream investment, resulting in losses for PSUs, but also discouraged investments in energy efficiency on the demand side. In the long term, additional LNG supplies are likely to be needed, but would also be more expensive than the current price paid for Qatari LNG. If India wants to attract additional LNG in the long term, it will have to increasingly compete in global gas markets at prices potentially higher than the current ones; otherwise LNG supplies will be taken by other Asian markets such as China.

Pricing is also a key factor for the demand side due to some sectors sensitivity to gas prices:

Gas-fired plants must compete with coal-fired plants which are usually more competitive. However, in some cases gas-fired plants near production sources or import terminals could be more competitive than coal-fired plants, especially those using imported coal or domestic coal shipped over long distances. Gas use for fertilizer production depends on government policy towards dependency on other countries and subsidies, as fertilizers can be produced at a cheaper price in nearby Middle Eastern countries. Pricing will determine the balancing point between supply and demand. There have been some positive developments in the upstream sector resulting in an increasing participation of JV and private companies and a certain number of discoveries including Krishna Godavari KG-D6, but the NELP is also facing some shortcomings mainly linked to policy and pricing issues. India remains largely under-explored and major efforts have to be made in this respect to develop additional domestic supplies. Although India is also located near significant resources of gas in Turkmenistan and Iran, pipeline interconnections remain a distant prospect. India has been turning to LNG instead and is building new regasification terminals, which will increase the existing capacity by half. Future supplies in the coming five years will be therefore based on two sources: domestic production and LNG supplies. The current capacity of gas based plants is mainly for base-load because there are shortages for electricity and also shortages of domestic coal. Gas has played an increasing role in power generation within utilities and even more in the case of captive power plants.

Power shortages have resulted in high prices for electricity and these have helped the gas-based power plants which have improved PLF even when gas prices have increased in the Indian market.

In the future,

Gas competes with coal for base-load capacity in scenarios where domestic coal supply remains constrained. Base-load gas power plants are competitive vis--vis coal plants when relative difference between gas and coal prices is below US $ 4 per MBtu. At higher than $ 4 per MBtu price difference, gas is competitive only for peak power supply. The future price expectation for coal, in all scenarios, is around US $ 3 per MBtu. Thus, the market clearing gas price is around US $ 7 per MBtu. The rightward shift in coal supply curve in the High Growth, Coal Reforms and Coal by Wire scenarios therefore makes coal more competitive vis--vis gas in base load generation. In the Coal by Wire scenario, the incremental transmission cost of mine-mouth coal power plants makes gas power plants competitive at demand centres located far from coal mines and nearer to gas supply points. International gas pipelines help in making gas competitive with respect to coal in northern gas markets which are far from coal deposits. In the electricity sector coal and gas have emerged as two very competitive choices which have given flexibility to power producers. The flexibilities are a result of reform policies like coal sector reforms and generation reforms. This flexibility results in a high elasticity of substitution between the two fuels. In the high growth scenario as a result though the overall demand for gas is higher the demand for gas from power sector is lower owing to higher demand from other sectors.

In the coal reforms scenario the flexibility allows power producers to shift faster to coal when there is a right-ward shift of coal supply curve.

The future demand for gas in India from the electricity sector under alternative scenarios for the period 2005-25

The electricity sector is among the key users of natural gas in India. An assessment of demand from Electricity Sector transporting power to demand centres is used by power producers to overcome the rail infrastructure bottlenecks and substitute gas from base load power generation. The sustained electricity deficit and environment policies have added to an already rising demand for gas. Post 1994, the market reforms have led to increased gas supply from domestic production and imports. The scenarios are differentiated by alternate economic growth projections and policies related to coal reforms, infrastructure choices, and local environment. The results across scenarios show that gas competes with coal as a base load option if price difference is below US $ 4 per MBtu. At higher price difference gas penetrates only the peak power market. Gas demand is lower in the high economic growth scenario since electricity sector is more flexible in substitution of primary energy. Gas demand reduces also in cases when coal supply curve shifts rightwards such as under coal reforms and coal-by-wire scenarios. Local environmental (SO2 Emissions) control promotes end of pipe solutions (FGD) initially, though in the longer term mitigation happens by fuel substitution (coal by gas) and introduction of clean coal technologies (IGCC).

Gas based Power plants: An economic blunder?

Power generation in India is heavily dependent on coal. However, recently, gas based power generation is slowly picking up and it contributes to around 10%- 11% of the total power capacity. In a scenario where gas supplies are officially falling short and imported gas prices continue to rise, will this shift make sense?

Is the timing right?

As domestic gas has been officially announced to decline and international gas prices remain high and volatile, financial viability of such gas based power projects is called into question. Especially because the basic raw material, natural gas, is highly in demand, in other sectors which can afford it. The existing domestic fields can assure gas supplies only till 2016, unless new discoveries are made. The imported gas is too volatile and costly at

current levels. Besides, too much reliance on imported gas jeopardizes the energy security of the nation.

Gas based versus conventional power plant

A natural gas based power plant has a shorter gestation period (less than 3 years) and lower fixed costs as compared to conventional power plant (3- 4 years). However, a gas based power plant makes sense (16% of RoE) over a coal based one if gas costs remain below or at US$7 per mmbtu. If the gas prices rise above US$ 10-US$ 12, it leads to unviable economics for the power sector. In last one year, the spot natural gas prices have risen by 50%. This has turned power generation companies averse to the use of spot LNG. The power companies have stopped buying gas from companies like GAIL and Petronet (PLL)

Logically speaking....
Using plain economics, any resource that is in short supply should be used in the order so that the value addition is maximized. It will make more sense to use imported gas supplies in the sectors where they can be afforded at market prices like transport, cooking gas, refineries and gas retailers etc. This is because no matter how high the price of imported gas is, it will still be cheaper than oil (the substitute fuel for natural gas), 80% of which is imported by India. These sectors will willingly shell out high gas prices (still cheaper than other options like Petrol/diesel and LPG). Again, competitive bidding for power projects has shown that base-load power even from imported coal is mostly cheaper than gas-fired power at current gas prices. Hence, using gas for power generation is economical neither for power nor for other relevant sectors (where the marginal economic utility of gas is higher). Around 40% of the gas supplies serve Power sector. It will be much better to use gas as a substitute for oil rather than coal. Its value addition for other sectors like industrial fuel and for cooking and transport purposes is much better. The reason is that country is more self sufficient in coal rather than in oil. Such a move will also strengthen energy security of the nation.

The fairness principle...

Unlike the base power plants which will be reluctant to pay more than US$5.8 per mmbtu, the industry users like refineries and petrochemical

plants would be willing to switch to gas up to fairly high gas prices (US$17-18 per mmbtu). Also, gas will be a much better (cheaper) substitute for diesel and petrol and unsubsidized cooking fuels rather than coal (coal based power plants).

Any allocation of funds for such gas based power projects may turn out to be bad investment and may kill or raise the costs of funding for other profitable and viable projects. Long term security of the fuel through which power will be generated is imperative. The companies need to understand the cost bearing capacity implications which they are prepared to bear. Recently, GAIL forayed into gas based power generation. This is a big boost to companys position along the value chain and potentially a sound business decision if domestic gas supplies increase in the near future. The companys RoE in the past few years has hovered above 19%. This compares to an approximate 16% RoE of a gas based power plant at US$7 to US$ 8 per mmbtu of gas costs (it is at this level that use of gas in a power plant makes more sense than coal).

The parallel implications...

PLL had struck a contract with Australia for gas supplies for its upcoming terminal at Kochi. Now, GAIL, the marketer of RLNG (regasified liquid natural gas) is in a fix as there are no off takers for this gas and GAIL had entered back to back agreement with PLL for this gas. The deal has turned out to be ridiculously expensive as the delivered price turns out to be US$ 20 per mmbtu versus a cost of US$ 15.6 per mmbtu for the imported gas from Qatar. The single biggest consumer of this gas, NTPC (for its power plant at Kayamkulam) is not for ready to pay such exorbitant prices at existing power tariffs and has insisted for a price rollback. If GAIL enters power markets with use of this gas, it will definitely strengthen the case for gas price pooling which will make it easy to sell its expensive gas. This is because it will narrow down the relative difference between price from other cheaper gas sources and costlier imported gas. However, the move will be negative for market determined pricing of natural gas (a concept opposed to pooled gas prices). It should be noted that while pooling/averaging out prices of domestic and imported gas may benefit companies like GAIL and Petronet (they are finding no users for contracted

imported gas supplies because of the high differentials in domestic and imported gas supplies).

Coal-fired power offers advantages over gas-fired power if the natural gas price is high and/or volatile, or in light of supply security issues. New coalfired power plants have higher efficiency and lower emission of CO2 per kWh than existing plants. Emissions of airborne pollutants may be lower as well. A disadvantage is the high investment cost (compared to gas-fired power) that is compensated for by the lower fuel cost.. The current price in the global emission trading system is not high enough to discourage the construction of new coal-fired capacity. In the near future, the utilities that have to comply with emissions trading systems may consider implementing CO2 capture and storage technologies (CCS). This may significantly increase the investment cost and reduce the efficiency of coal-fired power. Therefore, long-term emission reduction policies and high CO2 prices are needed for CCS to become commercially available. Coal-fired power not only competes with gas-fired power, but also with nuclear and renewable power.