ChamberRVA supports DEQ Guidance APG-578 “Sudden and Reasonably Unforeseeable Events in the Context of Planned Electric Outages”

• Emergency generators are in place at manufacturing facilities, hospitals, schools, and a wide variety of other businesses and government operations. The purpose of these generators is to enable operations to continue despite a loss of electricity.
• The regulations define such emergency events as being sudden and reasonably unforeseeable and outside the control of the operator of the business.
• Power suppliers conduct maintenance work based on the need of the energy distribution system, the equipment on site, and other considerations. Power suppliers decide when they will shut down to perform such maintenance, often with little or no notice to the businesses that rely on the energy they supply. 
• Given the significant number of operations impacted by a power station shut down, it is difficult to obtain temporary generators or upgrade existing generators on short notice (14 days or less).  Even where temporary generators can be obtained, they often produce equal or greater emissions from the emergency generators already on site. 
• Guidance APG-578 provides a practical interpretation of the regulatory language that recognizes the purpose of the emergency generators and the constraints on operations due to power station shut downs with limited notice, while including safeguards that are protective of air quality.