I urge you not to loosen the limits on emergency generators.  Stick with the original definition of “emergency,” which protects our health by restricting the occasions when they can run and moreover, makes sense.

I also urge you to ban, or severely restrict, the use of Tier 2 generators.  You are certainly well aware of the risk to our health that they cause, and please consider the cumulative effect:  in Virginia about 9,000 Tier 2 generators have been permitted, with over half of them in eastern Loudoun County.  During an emergency they would all be running, with scary consequences for our air quality.  And remember that those residents were assured that the generators would only run on rare emergencies.  Those residents deserve a valid, well-documented reason for any increase in generator use.

Instead of generators, consider battery storage.  Iron-air batteries are being developed for multi-day grid backup, are safe and made from low-cost materials that are readily available.  At this point they are too expensive for data center use.