PEC Supports New Standards on Non-Emergency Generators

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PEC sent the following letter to the Pennsylvania House Environmental Resources & Energy Committee.

January 13, 2014

To:      Members of the House Environmental Resources & Energy Committee
From:  John Walliser, Pennsylvania Environmental Council
Re:      Support for House Bill 1699 (P.N. 2382)

On behalf of the Pennsylvania Environmental Council (PEC), I am writing to express our support for House Bill 1699 (P.N. 2382). This legislation, which will be considered by the Committee on January 14th, requires registration, emissions standards, and reporting for non-emergency, stationary demand response generators.

Demand response is principally a strategy aimed at reducing consumption of electricity during times of peak demand. However, in some cases, small electric generation units – the overwhelming majority of which are diesel fueled – are also used. Many of these generation units are now selling electricity “behind the meter” back into the grid system in non-emergency situations, exempt from federal pollution control standards. Although these generation units operate infrequently in comparison to base load sources, they are a significant regional source of Nitrogen Oxide (NOx) emissions, which present human health impacts and impede attainment of ozone and fine particulate National Ambient Air Quality Standards.

HB1699 would utilize established emissions standards for all non-emergency generators, and enhance transparency through registration, reporting, and auditing requirements for these units. We support the intent and framework of HB1699, and encourage you to consider the remarks made by Vincent Brisini from the Pennsylvania Department of Environmental Protection at the Committee’s November 20th hearing on this legislation with respect to the application of standards pursuant to Section 4 of the legislation.  In addition to those comments, for existing units that may be required to install pollution controls or meet emission standards as a result of this legislation, we note that those controls or standards should be consistent with federal standards for existing non-emergency units under 40 C.F.R Part 63, Subpart ZZZZ.

We strongly urge you to support this important legislation on January 14th.

Thank you for your consideration.