Comments to EPA on Proposed Rule for GHG Emissions for New Stationary Sources (NSPS)

The Alliance to Save Energy submitted comments to the Environmental Protection Agency on its proposed New Source Performance Standard (NSPS) that would impose carbon dioxide limits on certain new fossil fueled utility electric generating units.
 
The Alliance’s comments focused exclusively on energy efficiency aspects of the proposed rule, including the use of an output-based standard (that is, basing emissions limits on useful energy derived rather than per unit of fuel burned) and crediting of useful thermal output from combined heat and power (CHP) facilities. The Alliance recommended several enhancements to the CHP-related provisions, including a definition adjustment, greater crediting of useful thermal output and provision of guidance on appropriate thermal applications. Further, the comments ask EPA to recognize and incentivize energy efficiency, including state and regional efficiency programs, in any future regulation that the Agency may develop pursuant to the Clean Air Act for existing electric generating plants.