EPA Reconsideration of the 15 Hour/Year Rule

Thanks to the efforts of several of our readers the negotiations with the EPA concerning increasing the 15 hours/year for emergency Demand Response (DR) are going very well.  In addition, the EPA issued an approval for reconsideration of the NRECA petition which is asking for Peak Shaving relief.  Soon there will be a Federal Register (FR) notice asking for comments.  At that time we will prepare a write-up explaining what to comment on, when to submit the comments, and where they need to be sent.  We can also provide some boilerplate language you can use in crafting letters to the EPA.  The FR notice should appear in a few weeks.

Note:  Caution should be exercised before committing EPSS assets to long term DR contracts.  Four of the ten major points to consider include: age of equipment, critical load isolation, system redundancy and local air permitting issues.

NRECA Approval Letter

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