By Jesse Berst

 

Delaware's environment department and others are raising concerns about a possible new EPA rule. On May 22, EPA proposed to increase the amount of time backup diesel generators can run as part of demand response (DR) programs. Today they can operate for 60 hours per year before triggering emission control mandates. The proposal would take it to 100 hours.

 

Opponents want to see backup diesel generators restricted to true emergencies, where they have always been exempt from pollution controls. "Are we relying on dirty

DR to replace retired coal capacity, instead of providing appropriate market signals to help develop cleaner alternatives?” asked Ali Mirzakhalili, director of the air division in Delaware’s environment department. He was quoted in the July 6 issue of Inside EPA., a weekly newsletter produced by Inside Washington Publishers.

 

Mirzakhalili told a meeting of the Mid-Atlantic Distributed Resources Initiative (MADRI) that “allowing the use of diesel generators for meeting peak electricity demand will discourage construction of new and cleaner resources” and make it harder for the state to meet EPA air standards. He pointed out that DR programs give the owners of diesel generators a financial incentive to run more often, even when there is not an actual power outage.

In the interview with Inside EPA, Mirzakhalili said the EPA proposal has “opened the gate” for diesel engines to “participate and be a problem.” The newsletter also reported that power companies such as Calpine, the Electric Power Supply Association and PSEG Energy Resources & Trade have been lobbying the EPA and the White House to oppose the new rule. The EPA is taking comment through July 23, with a final ruling due in December.

 

Meanwhile, a coalition of environmental groups is ratcheting up the volume even more, calling the proposed rule "a free pass for toxic air pollution" in a recent press release. "EPA's proposal would create a loophole allowing dirty generators to participate in profitable electricity market programs, giving them additional revenue while avoiding life-saving pollution controls," said Courtney Lane, senior policy analyst at the PennFuture Energy Center.

 

"Don't tell mothers that the only way to ensure a stable electric supply is to put their kids' health in danger," pleaded Mark Kresowik, eastern region deputy director for the Sierra Club's Beyond Coal campaign.

 

What do you think? Could the debate tarnish DR's image around the country? Use the Talk Back comment form below to share your thoughts.

 

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Jesse Berst is the founder and chief analyst of Smart Grid News.com, the industry's oldest and largest smart grid site. A frequent keynoter at industry events in the U.S. and abroad, he also serves on advisory committees for Pacific Northwest National Laboratory and the Institute for Electric Efficiency. He often provides strategic consulting to large corporations and venture-backed startups. He is a member of the advisory boards of GridGlo and Calico Energy Services.

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Emergency Demand Response

Our current emergency demand response procedures call for the use of back up generators at our facilities and customer facilities when manual load shedding is directed by the system operator, transmission service provider or due to internal system contingincy. My agency is based in the South Coast Air Quality Management District in Southern California which has severe restrictions on generator emmissions.

Steve Lafond - 07/12/2012 - 06:47

Diesel generator MYTH

The opposition to this initiative are confusing the two forms of diesel that are used for power generation, #2 vs #6. The diesel generators the industry uses for this application use #2, low sulphur, which is very clean. They are almost as clean as natgas generators. These generators are cleaner than heating oil furnaces and diesel powered vehicles. They are confusing these with generators that burn #6, bunker oil. That type of plant requires extensive pollution controls. This confusion has been going on so long that it is now willful and demagogic. ~James Carson, RisQuant Energy

James Carson - 07/12/2012 - 07:49

Diesel Engines for Demand Response

Mr. Carson has a valid point in many ways. Being able to utilize these assets for limited periods when they run fairly clean is a smart thing to do. For the Sierra Club to continue to pull this "...don't tell mothers...put their kids' health in danger..." is a lot of histrionic crap, if not downright lying. What is better, 1) allowing these firms who installed these units to ensure they have power in emergency situations to make a bit of money off the units; 2) constructing new plants that result in further land damages and higher electricity costs for everyone for only a few hours of running each year; or, 3) causing some business, manufacturing facility, or homes to lose power for a couple hundred hours a year? That's one of the problems with the more rabid environmentalists--they are willing to let others suffer the loss of electricity as long as they, themselves, don't.

Byron - 07/12/2012 - 08:26

Careful Comparison

Folks need to be careful in their public comparisons. For example, coal generation is baseload, distributed generation for demand dispatch addresses peak demand, not baseload. Peak demand is independent from coal-based generation. The true comparison is between using natural gas fired central-station peaking units or distributed generators (mostly diesel) to address peak demand. In this case, there is an argument that dispatchable diesel DG creates less emissions than natural gas peakers. The up ramping time and down ramping time for natural gas peakers is much greater than dispatchable diesel DG which is quick on and quick off. Thus, the total emissions profile is less for the diesel DG to address the same peak demand (kW over time). The industry and the environmental groups need to tell the mothers the whole truth and nothing but the truth.

Steven Pullins - 07/12/2012 - 08:40

Southern California Regulations

As Steve Lafond points out use of emergency generation during outages is permited but I did check with our experts here at Burbank on the SCAQMD regulations and confirmed that: AQMD permits for emergency generators typically restrict its use to 20 hour/year for maintenance and testing purposes. There is usually a limit of up to 200 hours for emergency use. This 200 hours doesn’t have to be a government declared emergency, just a loss of main power. In a declared emergency, the 200 hour limit may be exceeded. The customer may not use the standby equipment to routinely provide extra power when needed, it must be an uncontrolled not an elected outage, unless the equipment is permitted for this type of use. Generators can be used to supply temporary power at remote and construction sites that don’t have a main power supply. In the SCAQMD using standby units on an elective basis may not exactly be aligned with the rules.

Fredric Fletcher - 07/12/2012 - 09:32

why avoid emission mandates?

If we are talking about cleaner forms of diesel generation, why do they need to be exempt from emission standards? Shouldn't operators of clean plants push for tighter regulations of emissions to crowd out less efficient plants? Ignoring the rhetoric, S.C. has the right of it , standards remain in place, if not increased.

Mark Costa - 07/12/2012 - 16:58

Today's Diesel Engines are Efficient

Today's Power Modules/Generator Sets are efficient and outperform the emissions of most commercial trucks. These engines utilize the most advanced electronic fuel systems to limit particulate emissions. Also, these diesel reciprocating engines are the best prime-mover for emergency/standby power. Therefore, why not utilize these generating assets if they can eliminate or delay the construction of conventional generation plants? The emissions from the additional 40 hours of generator runtime will be negligible compared to total diesel engine emissions from commercial vehicles. By the way, if you are interested in reducing SO2, CO2, hydrocarbons and particulates, then you can blend biodiesel with diesel. Unfortunately, NOx could increase from the use of biodiesel and this could lead to potential smog problems. Studies have shown mixed results using these biodiesel blends when it comes to NOx emissions. If you think that natural gas is the solution, then understand that these engines are less efficient and will increase CO2 (green house), CO (poison), and hydrocarbons (known to cause cancer). It would slightly reduce NOx and it would reduce particulates. Please understand that there are no zero emission engines for producing power, but the technology continues to improve and I think biodiesel could provide some additional improvements (except for NOx) in emissions output.

Todd Sumner - 07/13/2012 - 05:33

The Article is Factually Inaccurate

This article is factually inaccurate. I am an air quality meteorologist who has been permitting sources since 1981 and who has been permitting engines in emergency demand response (DR) programs since 2002. I have worked directly with states and the EPA on this issue for many years. The EPA’s proposed rule (RICE NESHAP) does not increase the annual operating hour limit for engine use in emergency DR programs from 60 to 100, as the article states - it restricts operation for emergency DR to the *lesser* of program requirements (which is 60 hours in PJM) and 100 hours. The EPA has always allowed up to 100 hours per year for non-emergency use, which includes testing and maintenance, and a subset of those hours for emergency DR. The EPA is not proposing to change this 100 hour annual limit – it is just being more flexible as to how those hours can be used in order to maintain last line of defense emergency resources to help prevent blackouts. It’s important to keep in mind that these generators – at hospitals, wastewater treatment plants, and other mission critical facilities – must run periodically for testing and maintenance, and existing permitting rules limit such operation to 100 hours per year. DR event hours can and are used as substitutes for normal testing and maintenance. Also, EPA is proposing to tighten the trigger for when emergency DR events can be called (i.e., at NERC EEA Level 2 and voltage reductions only); thus, emergency DR is very rarely called. The last, and only time, emergency engines have been used by ISO New England for emergency DR, for example, was on August 2, 2006 for a total of 3.75 hours. If emergency DR was not available that day, the grid most likely would have failed; and if that happened, every generator, whether properly permitted or not, would have operated for hours or days before the electric grid was restored.

Don DiCristofaro - 07/13/2012 - 09:30

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