The Alliance submitted detailed feedback to EPA on the design of its anticipated 111(d) rule, a program to reduce carbon pollution from existing power plants. Our letter highlights the carbon benefits of CHP and waste heat to power, demonstrates that these technologies are cost effective and adequately demonstrated, and profiles actions that states and utilities are currently taking to encourage greater deployment of these technologies. The Alliance encourages EPA to clarify in its emissions guidelines that policies that create opportunities for CHP and WHP would support an equivalency determination; and that states, in turn, should take steps to encourage CHP and WHP as part of their compliance plans.
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