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federal facilities would save taxpayers $13 billion annually. Beyond simply encouraging or even requiring federal facilities to take advantage of the efficiencies of CHP for the long-term savings for the taxpayer, there are other concrete steps that the Federal government can engage in to encourage the deployment of CHP technologies. For example, as the EPA implements its Boiler MACT emissions standards, CHP should be strongly encouraged as a compliance strategy for those currently burning coal or oil. DOE’s Clean Energy Assistance Centers can provide site-specific technical and cost information to facility managers. Similarly, we hope states will look to EPA’s guidance on output-based emissions regulations, which recognize both the efficiency and pollution prevention benefits of CHP, unlike input-based standards. Output based standards encourage cost-effective, long-term pollution prevention through process efficiency. We also want to work with utilities to demonstrate the benefits that CHP can bring to the grid as a clean, distributed resource. Both states and utilities should include CHP in energy strategy and resource planning efforts. Likewise, we were glad to hear FERC propose reforms for small generator (<20MW) interconnections to reduce the time and cost to process requests and allow for more efficient interconnection of distributed resources. The CHP industry is eager to be an active participant in these discussions. We hope guidance to state regulators on common and fair interconnection standards and rates for CHP will be heeded. Finally, as Congress considers how to address the need for comprehensive tax reform, we note that there are several technologies that currently benefit from government support though various levels of an Investment Tax Credit. We believe the lack of parity in support levels for decentralized and renewable energy technologies blur the market place and does not properly encourage the deployment of the best technologies or the technologies that provide the most benefit to the system. We support parity in the treatment of the various types of clean energy sources and would 9PDF Image | For the House Energy and Commerce Energy and Power Subcommittee hearing:
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