Yesterday, EPA released proposed revisions to its rules
governing emissions from emergency back-up generators. It's not
always the most exciting of topics, but it is important. Many
facilities have back-up generators and I know from experience
advising clients that, precisely because back-up generators do not
run that often, operators can run into compliance issues.
The most important aspect of the proposed rule is that EPA would
allow back-up generators to run for up to 100 hours without being
subject to emissions limits for the following reasons:
Monitoring and testing
Voltage changes of at least 5%
Moreover, EPA is proposing that, through 2017, emergency
generators be allowed to operate without limits for up to 50 hours
of this 100-hour exception "for peak shaving and non-emergency
demand response." EPA's explanation is that this temporary
exception is necessary "to address reliability issues and
develop solutions to reliability issues while facilities are coming
into compliance with the" utility MACT rule.
I find it interesting that, according to the Daily Environment Report, the Electric Power
Supply Association opposes the rule. EPSA President John Shelk was
quoted as commenting that:
The essential design and purpose of
demand response is to encourage consumers to reduce their
consumption of electricity in response to appropriate market
signals, not to simply replace power from the grid with power from
an on-site emergency diesel generator not subject to the same air
This is actually something of a difficult issue. Back-up
generators are an important element of flexibility in grid
operations. On the other hand, EPSA makes a fair point that one
does not typically think of utilization of back-up generators as a
component of "demand response".
Indeed, one could fairly think of use of back-up generators as a
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