Virginia Regulatory Town Hall
Agency
Department of Environmental Quality
 
Board
Air Pollution Control Board
 
Guidance Document Change: DEQ Guidance Memo APG-578 addresses the use of emergency generators in the case of “sudden and reasonably unforeseeable events” as the result of a planned electric outage.
Previous Comment     Next Comment     Back to List of Comments
11/25/25  8:46 am
Commenter: Elspeth McCormick

Protect Public Heath As Primary Mission
 

Protecting citizens must always remain the DEQ’s highest priority. Regulations should never be relaxed to benefit any industry if doing so compromises public health.

Allowing emergency generators is not acceptable, as this would introduce more unnecessary pollution and set a dangerous precedent, potentially resulting in these generators being used for demand response during grid stress—contrary to their intended purpose.

Tier II generators should not operate near sensitive receptors (e.g., schools, hospitals, parks, trails, residential areas) during planned outages. Public notice must include generator locations, schedules, and duration. Emergency generator sites require daily inspections for fuel use and must have air quality monitoring throughout operation.

CommentID: 238023