If I'm decoding the proposed change's description correctly, the "source" refers to a pollution-source, aka a power-consumer.

And, if I understand the proposed regulation correctly it would let a power-consumer light up their emergency generators if and when a power-supplier gives that consumer fewer than 15 days’ notice before a planned power outage.

Furthermore, the change description points out that power-consumer's emergency generators can use low-quality emission-reduction techniques (those generators can fall short of Tier 4 or better emission controls).

Finally, the proposed regulation change's description makes no mention of whether or not getting such a notification from their power-supplier might violate the service level agreement (SLA) established between the power-supplier and the power-consumer.

Perhaps I'm being naive, but if a power-consumer that failed to negotiate a sound SLA or that failed to anticipate the consequences of an SLA they chose to accept, now wants neighboring residents and businesses to put up with the air and sound pollution that the consumer's emergency generators will create during non-emergency situations; I'm not inclined to solve that power-consumer's problem by harming the health and/or profitability of the consumer's neighbors.

In other words, because I'm confident "planned" outages do not occur on short notice in the power-generation and transmission industry, I think it takes a lot of misplaced bravado on the part of the power-consumer to try to trick other people into picking up the bill for that power-consumer’s poor planning (or desire for increased profits). I’m confident that non-emergency outages are planned months in advance, not days, and I’m strongly suspicious that this proposed change is a fig-leaf cover up a desire to simply not pay for expensive alternate power-sources.

The Virginia SCC needs to force power-suppliers to uphold the suppliers’ end of the suppliers' SLAs, and the Virginia DEQ needs to tell power-consumers to not beg other Virginians for relief when the supplier abides by that same SLA.

If power-consumers haven't lined up adequate, clean, non-emergency power-sources to use during planned outages, that's the power-consumer's problem - A problem that can and should be solved without resorting to using emergency generators. The solution will probably involve more time or money than the power-consumer wants to invest, but poor-planning on that power-consumer's part isn't a reason use their neighbors' health and profitability to subsidize those power-consumers.

Claiming a planned outage is also unexpected is ridiculous. One side or other in the supplier-consumer relationship is being disingenuous.

Don't incentivize poor planning by adopting this proposed APG-578 change.