WADE Comments on the EPA's Proposed Rule to Limit Carbon Emissions from Existing Power Plants

WADE recently joined forces with other industry members to submit comments to the Environmental Protection Agency (EPA) on the proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (EGUs) under section 111 (d) of the Clean Air Act. The EPA rule is designed to cut carbon dioxide emissions from existing coal plants by as much as 30% by 2030 compared to 2005 levels. Nearly 2 million comments were submitted to the EPA on the proposed rule.

The rule is scheduled to be finalized in mid-2015 and then each state will have a year to design plans for meeting the emission reduction goals. Many industry members agreed that rule presented an opportunity to promote the energy efficiency and emissions saving benefits of cogeneration/CHP and other decentralized energy options.

WADE worked with other cogeneration and combined heat and power industry members and submitted comments that echoed those submitted by the Combined Heat and Power Association. The comments requested that EPA provide clear guidance to states so that rule compliance not impose regulations on existing CHP facilities and that the EPA should clarify that voluntary CHP retrofits and upgrades at affected EGUs are an approvable compliance strategy

CHP also played a featured role in the comments submitted by The American Gas Association (AGA). The AGA comments supported the compliance flexibility that the EPA has built into the proposed rule and requested that the EPA's final rule make it clear that states are allowed a variety of compliance options to include the direct use of natural gas in their state plans. The AGA specifically requested that the EPA give states clear guidance on how they can successfully incorporate CHP into their rule implementation plan since natural gas is the preferred fuel choice for CHP applications. In a press release following the comment submittal, the AGA stated "Commercial, industrial and institutional facilities around the country can achieve real savings while reducing emissions by utilizing CHP" and cited a report released last year that the AGA worked on with ICF International titled "The Opportunity for CHP in the United States" that indicates that more than 40 gigawatts of potential CHP could achieve a 10-year payback or less.
For a copy of the report go to: Click Here.

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