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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11/24/25  4:26 pm
Commenter: Dana Kincaid

Do not broaden Emergency Generator allowance
 

Do not broaden emergency generator allowance, even for planned outage events.
DEQ must put protecting public health first as their primary mission above all else. The Data Center does not get priority over citizens.  Increasing the allowance 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.
Even with current allowances, strict limitations and regulations should be incorporated:

    • 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.

Again, DEQ must put protecting public health first as their primary mission above all else. 

CommentID: 237988