100 Hour Annual Limitation - Another Question

Q.  Does an electric utility’s request for you to run your generators under a building load count against the 100 hour annual limitation on operating emergency generators for testing and peak shaving?

A.  The Environmental Protection Agency (EPA) in June 2006 issued final requirements to reduce emissions of air pollutants from stationary compression ignition (CI) internal combustion engines (ICE), also called stationary diesel engines. As part of those requirements an annual limitation on using emergency generators for peak shaving and load-sharing (as well as testing) was set at 100 hours.

Two interesting questions have arisen this week as to an interpretation of what constitutes an emergency use, and therefore not subject to the 100 hour limitation. Specifically, “If the utility asks us to run to help keep the grid on line, can this be considered an ‘emergency’ under the new rule”; and, “when hospitals are asked to load shed, can these generators be attributed to the utility's carbon footprint and therefore receive some consideration?”

We will keep you posted on the EPA’s response.

Please email your thoughts (dan.chisholm@mgisys.com).