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Compliance Options Should Include Industrial Energy Efficiency

WASHINGTON (January 21, 2016) - The American Chemistry Council (ACC) issued the following statement upon submitting formal comments to U.S. Environmental Protection Agency (EPA) regarding the Agency's proposed federal plan and model rules for the Clean Power Plan .

" Energy efficiency helps reduce greenhouse gas emissions while minimizing consumer costs and enhancing the competitiveness of U.S. manufacturers. Power plants and states should have choice and flexibility as they strive to reduce emissions, yet many of the most promising strategies are not included in the Clean Power Plan.

"We urge EPA to make eligible and fully credit industrial energy efficiency, such as combined heat and power (CHP) and waste heat to power (WHP); biomass; carbon capture and storage (CCS); and third-party demand-side energy efficiency programs. These resources will help reduce emissions, boost overall fuel efficiency and improve the reliability of the power supply. Industrial consumers, especially those in electricity-intensive sectors, are particularly vulnerable to impacts related to the design of the federal plan.

"As proposed, EPA's federal plan and model rules would needlessly harm portions of the U.S. manufacturing sector and limit the compliance options available to affected power plants and states. At the same time, we continue to question whether EPA has the legal authority under the Clean Air Act to fundamentally change and regulate our nation's electricity system."


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