The CHP Association submitted its comments to US Environmental Protection Agency under section 111 (d) of the clean air act.
Some highlights of the comments include:
CHP facilities should not be regulated under the Proposed Rule. EPA should ensure that CHP facilities are not inadvertently subject to regulation under the Proposed Rule as “affected Electricity Generating Units.” In particular, EPA should provide clear guidance to the states that their compliance plans should not impose regulations on CHP facilities.
CHP facilities should be credited as a voluntary compliance solution. EPA should provide clear guidance to the states on how their compliance plans can credit CHP facilities for their voluntary contributions to reducing emissions from “affected Electricity Generation Units.”
As a fundamental principle, it is our view that no existing CHP facilities should be subject to regulation under the Clean Power Plan because: (1) the focus of the rule is on utility-scale electricity generation units; and (2) CHP facilities are providing substantial climate and other benefits.
CHPA urges EPA to include additional, express guidance in its final Clean Power Plan so that it is clear to the states that CHP is a voluntary emission reduction tool that can be incorporated into state compliance plans.
In its final rule, EPA should clarify that voluntary CHP retrofits and uprates at affected EGUs are an approvable compliance strategy. EPA should support and provide guidance for new and uprated CHP at facilities other than affected EGUs as an approvable voluntary end-use energy efficiency measure. EPA should clarify that CHP that combusts renewable fuels Is considered renewable energy.
For more details, please see the comments by clicking here.