I strongly oppose the adoption of Guidance Document APG-578, which would allow emergency generators to run during planned electric outages with as little as 14 days’ notice by redefining them as “sudden and reasonably unforeseeable” events.

This change directly contradicts the plain meaning of existing regulations (9VAC5-80-1110 and 9VAC5-540-20). Planned outages are foreseeable by definition and give facilities ample time to shut down or use cleaner temporary power.

Please withdraw APG-578 entirely and retain the longstanding interpretation that excludes scheduled outages from emergency provisions.

Thank you for your consideration.