The emergency generator allowance should not be broadened to include planned outage events. Doing so will contribute to more unnecessary pollution and put us on a path that could lead to these generators being used for demand response during periods of grid stress, which is not their intended use.

Let's be clear, DEQ should not be making this change. However, if DEQ makes this change, it should incorporate strict limitations and regulations including:

• Not allowing Tier II generators to be run for planned outages near “sensitive receptors” (e.g., schools, hospitals, parks, trails and residential areas)
• The public should be given notice about where and when these generators will be running and for how long.
• Each site where emergency generators are running should be inspected daily to monitor fuel usage and should be equipped with air quality monitoring for the duration of their usage, at a minimum. 

DEQ must put protecting public health first as their primary mission above all else. Demand accountability and solutions that are in the public's best interests. We're counting on you.