I have by no means made the effort to read all the comments, but I have gone looking for some of the more significant ones. Two that I can highly recommend are this one by a group of 21 red state AGs led by West Virginia, and this one by an overlapping group of 18 red state AGs led by Ohio. Both of those comments do an excellent job of dismantling the concept that either CCS or “green” hydrogen could ever work as a significant part of our electricity generation system. Of the two, the West Virginia comment is the much longer (54 pages) and goes into far more technical detail. But the Ohio comment, at 21 pages, has its share of good zingers as well.

The Ohio and West Virginia comments label the idea of CCS at the high rate demanded by EPA (90%) as either “infeasible” or not “viable,” and include recitations of the history of failed attempts to implement this frankly useless technology. From the Ohio comment (page 4):

A study of 263 carbon-capture-and-sequestration projects undertaken between 1995 and 2018 found that the majority failed and 78% of the largest projects were cancelled or put on hold. After the study was published in May 2021, the only other coal plant with a carbon-capture-and-sequestration attachment in the world, Petra Nova, shuttered after facing 367 outages in its three years of operation.