The Virginia Department of ENVIRONMENTAL QUALITY must protect public health as its primary mission. It should not be watered down. Thus, emergency generator allowance should not be broadened to include planned outage events. Such planned outage events would contribute unnecessary pollution and lead to a slippery slope of permitting the generators to be used for demand response during periods of grid stress, et al.

However, if DEQ does (unwisely) choose to make this change, it should incorporate strict limitations and regulations that include:

• Not allowing Tier II generators to be run for planned outages near "sensitive receptors," e.g., schools, hospitals, residential areas, parks, and trails
• Requiring that public notice be given about where and when the generators will run and for how long 
• Inspecting daily each site where emergency generators are running to monitor fuel usage and equipping such generators with air quality monitors for the duration of their usage.

DEQ should act responsibly in the interest of public and environmental health.