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.
DEQ must put protecting public health firstas their primary mission above all else.
The emergency generator allowance should not be broadened to include planned outage events.
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:
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
