Alliance Comments with Recommendations to Clarify and Strengthen Role of CHP and WHP in Virginia Carbon Reduction Plan

The Alliance for Industrial Efficiency submitted comments on Virginia’s proposed carbon regulation. The Virginia Carbon Reduction Plan is designed to reduce carbon emissions from fossil fuel-burning power plants by 30 percent by the year 2030 and establish a carbon trading market. It is an important and exciting step forward for the Commonwealth and we are pleased to be able to offer our recommendations for strengthening the rule.

Our five recommendations would further recognize the multiple economic, energy efficiency, and greenhouse gas reduction benefits that CHP and WHP systems provide. The first four recommendations apply to existing CHP projects and the fifth will help encourage additional CHP deployment. We recommend 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. 


You can read our comments here.