Posted by: philadelphiadieseldifference | January 5, 2009

Clean Air Council’s Comments Concerning PADEP’s Emergency Generator Plan Approval Exemption

From Clean Air Council:

Clean Air Council’s comments concerning PADEP Policy on Plan Approval and Operating Permit Exemptions (Document Number 275-2101-003)

Clean Air Council is a nonprofit environmental group established in 1967. For over 40 years, the Council has sought to protect everyone’s right to breathe clean air. On behalf of its more than 7,000 members who reside in Pennsylvania, the Council is concerned with one of the plan approval exemptions listed in PADEP’s guidance document 275-2101-003.

Specifically, under the Section 127.14 (a) (8)  exemptions that require the submission of a RFD form, item #45, internal combustion generators that participate in Pennsylvania-New Jersey-Maryland Interconnection LLC (PJM)’s Emergency Load Response Program (ELRP) and that do not operate in excess of sixty hours a year are exempt from plan approval requirements. PADEP differentiates “emergency” engine generators from “peak shaving” generators, which are not exempt from plan approval requirements. Clean Air Council believes this differentiation is neither wise nor warranted.

Allowing this “emergency generator” exemption will provide a loophole for utility companies. Rather than building new power plants subject to strict Clean Air Act regulatory controls to handle increased energy usage, the utility companies can claim the likelihood of a power outage and activate emergency generators not subject to regulatory controls. The time of the year where energy demand is greatest happens to correspond to when ozone pollution is at its highest: the summer. Emergency generators are an uncontrolled source of nitrogen oxides, which form ozone. Allowing unregulated emergency generators to operate during high ozone summer days, even if there is a sixty-hour per year limitation, will worsen the region’s air pollution levels.

Given that multiple regions in Pennsylvania are expected to be classified as nonattainment under the 2008 Ozone standard and that the Philadelphia area is still not in attainment of the 1997 Ozone standard, the Council believes this type of exemption is counterproductive. Clean Air Council opposes PADEP’s proposed exemption for emergency generators from plan approval requirements.

Respectfully Submitted,

Eric Cheung, Esq.
Senior Attorney



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