NJDEP Cracks Down on Emergency Generators

New Jersey Department of Environmental Protection (NJDEP) has begun to restrict certain specific uses of emergency generators.  NJDEP has learned that some facility owners and operators of these engines have entered into contracts with electric utility companies in order to use their emergency generators for purposes of peak or load shaving, demand response and similar programs.  ‘Demand response,’ as defined by the NJDEP, “is a preemptive action in which the participating facility voluntarily agrees to commence operation of its electrical generating equipment prior to the reduction in voltage or failure of electrical power in return for economic benefit.”  NJDEP would like to make clear that the operation of emergency generators for the purposes of peak shaving or demand response is permitted only if the generator in question includes air pollution control and the facility’s approved air permit contains conditions that allows the emergency generator to be used in this way.  Currently, the emergency generator general permit does not permit the use of a generator for demand response or peak shaving programs.  In order to participate in these programs, a facility would have to obtain a regular air Preconstruction or Operating permit approval from NJDEP.

For purposes of clarification, it should be noted that some stationary internal combustion engines used as emergency generators may be operated in situations without air pollution control devices.  These situations include:

(1) during the performance of normal testing and maintenance procedures, as recommended in writing by the manufacturer and/or as required in writing by a Federal or State law or regulation;

(2) when there is power outage or the primary source of mechanical or thermal energy fails because of an emergency; or,

(3) when there is a voltage reduction issued by PJM and posted on the PJM internet website (www.pjm.com) under the “emergency procedures” menu.

If an emergency generator is not operated in one (1) of the three (3) scenarios listed above, the equipment fails to meet the definition of “emergency” and is therefore subject to air pollution control requirements and a regular air pollution control permit.

If you desire to operate your combustion engine for peaking or demand response programs, please contact the NJDEP’s Air Quality Permitting Program to determine if your engine can qualify for an air permit for non-emergency use.

Additionally, ALL4 can help you through the permitting process as well.  Should you have questions, please contact either Ron Harding (610.933.5246 x119; rharding@all4inc.com), our in-house expert on stationary engines, or me (610.933.5246 x128; bchantz@all4inc.com) to discuss your air permitting needs.