Action | Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17) |
Stage | Proposed |
Comment Period | Ended on 3/6/2019 |
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March 6, 2019
Ms. Karen G. Sabasteanski, Policy Analyst
Office of Regulatory Affairs
Department of Environmental Quality
P.O. Box 1105
Richmond, VA 23218
RE: Comments of the Alliance for Industrial Efficiency on Proposed 9VAC5 Chapter 140 Regulation for Emissions Trading Part VII CO2 Budget Trading Program
Dear Ms. Sabasteanski:
The Alliance for Industrial Efficiency (the “Alliance”) appreciates the opportunity to submit our comments on the re-proposed 9VAC5 Chapter 140 Regulation for Emissions Trading, Part VII Carbon Dioxide (CO2) Budget Trading Program (the “proposed regulation”).
We commend the Department of Environmental Quality (DEQ) for recognizing the most economically efficient means for reducing CO2 emissions in the regulation: incenting energy efficiency. We also commend DEQ for granting certain industrial combined heat and power (CHP) and waste heat to power (WHP) units an exemption from the proposed regulation, which rightly recognizes the significant emissions benefits offered by these systems.
On April 9, 2018, the Alliance offered five recommendations that further recognize the multiple economic, energy efficiency, and greenhouse gas reduction benefits that CHP and WHP systems provide. The first four recommendations applied to existing CHP projects and the fifth would help encourage additional CHP deployment. We recommended that DEQ:
1. Eliminate ownership language in the applicability guidelines;
2. Define “primary use” and add system efficiency requirements to the applicability guidelines;
3. Add “or facilities” to account for district energy systems in the applicability guidelines;
4. Add a thermal energy use exemption to the regulation;
5. Explicitly state CHP and WHP projects are eligible for set aside funds.
The Alliance greatly appreciates DEQ accepting our recommendations for both eliminating ownership language in the applicability guidelines, and defining “primary use” in the applicability guidelines, as they provide important clarity for potential CHP hosts.
Furthermore, the Alliance urges DEQ to consider three other recommendations which will further encourage greater use of emissions-reducing CHP and WHP systems in Virginia in a way that is consistent with the goal in the Commonwealth of Virginia’s 2018 Energy Plan to deploy 750 Megawatts of CHP by 2030.
We thank DEQ for the opportunity to comment on the proposed regulation, and we are grateful for the emerging recognition of CHP’s benefits among Virginia policymakers.
Sincerely,
David Gardiner
Executive Director
Alliance for Industrial Efficiency