My comment is related to the Performance Standards for Fossil Based Electricity, Thermal
Energy Supply and Cogeneration:
"The performance standard for cogeneration would take into consideration the performance of an efficient natural gas-fired cogeneration system (e.g., 90% overall efficiency)".
90% is NOT achievable in any cogeneration system - the industry standard is around 60% to 65%
Submitted February 13, 2019 8:20 AM