EPA To Set Limits On Use of EPSS For Demand Response Contracts

On December 7 the U.S. EPA published a notice in the Federal Register requesting comments on the Notice of Reconsideration regarding the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal Combustion Engines in response to a petition filed in May 2010.  The EPA is accepting comments only on the 15 hour per year limit on the use of emergency engines in emergency demand response programs.  The  petition requested the EPA to change this limit to a maximum of 60 hours per year, or the minimum hours required by the Independent System Operator (ISO) tariff, whichever is less.  Comments are due on February 14, 2011.

Comments can be mailed, faxed, or emailed to EPA.  The easiest method is by email.  Make sure to include the Docket ID No. EPA-HQ-OAR-2008-0708 in the letter and email and send to: This e-mail address is being protected from spambots. You need JavaScript enabled to view it with a copy to This e-mail address is being protected from spambots. You need JavaScript enabled to view it .  To see a suggested template click here.

Demand Response, even though allowed indirectly and directly by NFPA 99 and 110 standards, and several local/state AHJS, it’s not a silver bullet that can/should be used by every facility.  In fact, the majority of acute care facilities are NOT candidates for several reasons even though regulations may allow participation in their geographic location.   There are 13 factors to be considered before deciding to use emergency equipment for economic benefit.  For this reason we are releasing a white paper outlining a suggested decision making process…including all pros and cons.

Dan Chisholm, Sr.
Emergency Power Consultant
Healthcare/Mission Critical Systems
PO 2474
Winter Park, FL 32790
407.421.7189
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