The Alliance for Industrial Efficiency appreciates this opportunity to comment on the Proposed Clean Power Plan (CPP) Model Trading Rules and Federal Plan.We appreciate that EPA repeatedly recognizes the benefits of energy efficiency in the Model Trading Rule and accompanying documents. We further appreciate EPA’s recognition that “CHP units are low-emitting electric generating resources that can replace generation from affected [electric generating units] EGUs” and that WHP can produce electricity with “no incremental CO2 emissions.”
