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Dear ARB,

The current list of early actions is heavy on transportation
impacts, but a significant portion of the CO2 generation
originates from the demand for energy, both electrical and heat,
in buildings throughout California.

A distributed network of small-scale (< 20kW) combined heat and
power (CHP) systems will bring significant economic and
environmental advantages to the State.  A clean fuel cell-based
CHP system will convert fuels to energy at a very high 85%
efficiency. Just as significantly, the carbon footprint of a
building could be reduced by 40%, as compared to NG peaker
generation plants and traditional natural gas space and water
heating. The building applications would include over 50,000 small
commercial buildings and a significant portion of the 12 million
homes in California.

The CHP systems and technology are available today to be
compatible with a variety of fuels, from natural gas to vegetable
oil.  The economic paybacks will be better than current solar PV
paybacks in California, while being able to produce 8 times the
annual energy output of a similar-sized solar PV installation.

The attached document was prepared for E2 (Environmental
Entrepreneurs) to use in its discussions with the ETAAC concerning
viable actions for AB32 implementation.  I will be happy to expand
on this and brief members of the ARB staff, at their convenience,
on our systems and capabilities in this area.

I encourage the ARB to consider incentives to accelerate the
deployment of clean, efficient small-scale CHP systems as one of
the early action recommendations to reduce greenhouse gas
emissions.

Most sincerely,

William R. Sproull
Sr. VP Business Development and Administration
ClearEdge Power, Inc.