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June 26, 2002

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Food Industry Cautions EPA, White House
on Clear Skies Initiative
Says cogeneration policy is at odds with other energy goals

Washington, D.C. – The Food Industry Environmental Council (FIEC), a coalition of more than 50 food processors and trade associations founded and chaired by the American Frozen Food Institute, recently sent letters to the White House and the Environmental Protection Agency (EPA) advising the Bush Administration of potential downsides associated with its current Clear Skies Initiative proposal.

The initiative, aimed at improving air quality through stricter emissions standards, includes a provision that would apply more stringent regulations to those operations deemed “electric generating units.” Of particular concern to the food industry, industrial cogeneration facilities, and specifically those found in the food-manufacturing sector, would be included in this definition of “electrical generating units.” American food manufacturers rely on combined heat and power, or cogeneration, for electricity production. Importantly, implementation of this initiative would be not only harmful to the food industry, but it also would be at odds with the President’s energy and global climate policies.

“Our industry depends heavily on cogeneration, which EPA has acknowledged is twice as energy efficient as traditional power production and produces comparably low emissions of conventional pollutants and carbon dioxide. In fact, U.S. Energy Information Administration data indicate that food manufacturing ranks first among the 65 non-utility industries generating electricity through cogeneration,” wrote FIEC members.

In its written comments, FIEC reminded EPA and the White House that many food manufacturing facilities use clean natural gas as the fuel of choice for cogeneration, thereby further reducing emissions. Furthermore, the President’s National Energy Plan recognizes the importance of cogeneration and includes recommendations to expand its use.

FIEC continued, “Regulating cogeneration under the Clear Skies Initiative would have little impact because emissions reductions from these relatively small units would be low while the retrofit costs would be high, inevitably discouraging use of cogeneration in food manufacturing and other industrial sectors.”

In its concluding remarks, FIEC urged the Administration to ensure the Clear Skies Initiative is consistent with the President’s other energy and climate goals by excluding coverage of cogeneration.

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The American Frozen Food Institute is the national trade association that has represented the interests of the frozen food industry for more than 60 years. Its 520 corporate members account for more than 90 percent of the frozen food production in the U.S.