Today, Alliance Program Manager, Jennifer Kefer, testified at one of 11 public listening sessions EPA is holding to solicit suggestions for its forthcoming greenhouse gas regulations for existing power plants (“The 111(d) Rule”). Her comments emphasized CHP and waste heat to power’s (WHP’s) substantial environmental and economic benefits and urged EPA to adopt a system-wide approach to emission reductions, so that utilities could receive credit for investing in these technologies. The Alliance further asked EPA to clarify that state policies that advance CHP would support an equivalency determination and to encourage states to take steps to encourage CHP and WHP as part of their compliance plans. You can find a written transcript of our remarks here.