CHP Alliance Submits Comments on DOE’s Supplemental Notice of Proposed Rulemaking (SNOPR): Clean Energy for New Federal Buildings and Major Renovations of Federal Buildings

Feb 21, 2023


February 21, 2023 (Washington, D.C.) — The Combined Heat and Power Alliance submitted a set of comments in response to the Department of Energy’s Building Technologies Office SNOPR, which revises federal building energy performance standards and requires reductions in federal agencies’ on-site use of fossil fuels for new buildings and major renovations.

The CHP Alliance urges DOE to consider all available technologies for compliance with the proposed rule, which would provide flexibility for federal agencies and encourage innovative solutions to achieve the overarching goal of reducing Scope 1 greenhouse gas emissions associated with on-site fossil fuel energy generation to zero by FY2030. To that end, our comments discuss:

  1. How the proposed rule could be strengthened by highlighting various pathways and technologies that federal agencies could use to meet target reduction levels;
  2. The use of zero emission fuels in combination with CHP systems and associated added benefits;
  3. How repowering existing CHP facilities to incorporate zero emission fuels is a viable compliance pathway for major renovations; and,
  4. Standards for calculating net GHG emissions for CHP systems.

You can view and download our comments here.