USCHPA ENVIRONMENTAL INITIATIVES

Output-Based Emission Policy

One of the USCHPA's key policy objectives is to persuade environmental policy makers that air regulation should provide credit to CHP for its exceptionally low emissions per unit of useful energy output. To the extent that emission allowances are issued to provide a market-driven means of lowering emissions, we wanted those allowances allocated on the basis of useful energy output, not fuel input, and to all users in an updated manner, including new ones, and not merely to grandfathered existing plants.

Federal Efforts--Multi-Pollutant Programs

For air pollution policy purposes as well as energy-efficiency policy purposes, a policy of updating output-based emission allowance allocation would be the best approach in any cap and trade program.

The USCHPA does not want a new CHP plant sponsor to have to purchase necessary emission allowances based on fuel input from a decades-old coal plant that obtained them gratis from the government, because that would effectively require the new, cleaner plants to finance the clean-up or shut-down of the older plants that have been exempted from clean-air rules for all these years. Unfortunately, the Administration's Clear Skies initiative would embody precisely these contradictions from the Administration's support for CHP for its environmental and efficiency benefits.

Our efforts to convince current leadership that this was feasible and beneficial made it clear that we needed a base of solid, technical analysis of how updating output-based allocations would work. We therefore commissioned Energy and Environmental Analysis (EEA) to perform a study, finalized in June 2003. EEA is the preeminent consultancy in this field.

• View Full Report: Analysis of Output-Based Allocation of Emission Trading Allowances (pdf)
• View Executive Summary (pdf)

State Efforts--DG Emission Rules/Permits

Visit the STATE POLICY EFFORTS page for information on regulatory proceedings for state DG Emission Rules.

CHP and Renewable Portfolio Standards (RPS)

Visit the STATE POLICY EFFORTS page for information on state regulatory and legislative proceedings involving RPS in Massachusetts and other states. More information on the topic to follow.