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.
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11/19/25  11:51 pm
Commenter: Anonymous

I oppose this proposal.
 

DEQ must put protect public health first as their primary mission above

all else.

 

The emergency generator allowance should not be broadened to include

planned outage events.

o This will contribute to more unnecessary pollution and put us on a

slippery slope that could lead to these generators being used for

demand response during periods of grid stress, which is not their

intended use.

• If DEQ chooses to make this change, it should incorporate strict limitations

and regulations including:

o Not allowing Tier II generators to be run for planned outages

near “sensitive receptors” (e.g., schools, hospitals, parks, trails and

residential areas)

o The public should be given notice about where and when these

generators will be running and for how long.

o 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 usag

 

CommentID: 237820