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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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