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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11/22/25  2:11 pm
Commenter: Colleen Bohlman

Opposed to expansion of emergency generator usage rules
 

Good afternoon,

I am writing to ask that the DEQ put protecting public health first as their primary mission above all others.  

specifically, the emergency generator allowance should not be broadened to include planned outage events.

this creates too much unnecessary pollution and noise.  
it increases the risk of these generators being used for demand response during periods of grid stress, which is not their intended use.  

We need safe, clean and quiet ways to power these facilities before we put them in everywhere!  Don’t allow the problem to grow by making their use more commonplace.  

If you feel this has to happen there should be strict limitations and regulations including:

    • Not allowing Tier II generators to be run for planned outages.
    • not allowing Tier 4 generators to be run for planned outages near “sensitive receptors” (e.g., schools, hospitals, parks, trails and residential areas)
    • The public should be given advance notice about where and when these generators will be running and for how long with a years notice.    Imagine trying to plan a wedding only to find out there will be generators running next to your church that day?  Emergencies are one thing. Planned use is another thing entirely.  
    • Each site where emergency generators are running should be inspected daily to monitor fuel usage and should be equipped with air quality monitoring by an independent entity for the duration of their usage.

Thank you,

CommentID: 237919