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Comment 6 for Cap & Trade Public Meeting (sept-9-chp-ws) - 1st Workshop.


First Name: Bill
Last Name: Buchan
Email Address: buchan@mktpotential.com
Affiliation:

Subject: But For CHP Option
Comment:
GPI applauds the “But For” CHP option currently under consideration
by ARB.  Under this option, the facility does not hold the
allowances; allowances are the responsibility of the natural gas
provider.  This option reflects the thinking under which our
facility and others invested in CHP.  We could have satisfied our
steam requirement with a simple boiler.  We recognized the
incentives CHP could provide with an additional marginal
investment.  If those incentives are not preserved, we could
convert our back-up boiler to full-time operation and shut down our
CHP.   This decision, while economically responsible for our firm,
would not benefit the state, as the state would ultimately see a
loss of base-load power.  The “But For” CHP option helps CHP
facilities preserve the incentives that allows us to continue
successful operation of CHP with power to the grid.  

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Date and Time Comment Was Submitted: 2009-10-02 15:49:04



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