The Connecticut Department of Energy and Environmental Protection (CTDEEP) published a draft set of responses to Frequently Asked Questions (FAQs) for any one currently operating an emergency engine that wants to enroll in ISO New England (ISO NE) - Demand Response Program.
The document explains that once an emergency engine is enrolled in DR, it is no longer considered emergency and would become subject to emissions limitations. Changing the mode of operation of the engine results in a “modification.” Modifications require a permit prior to operation if the proposed change in operation will result in an increase in potential emissions equal or greater than 15 tons per year (assuming the engine runs 24 hours per day, 365 days per year at maximum capacity). If the modification requires permitting, the application must contain a review of Best Available Control Technology and an analysis of ambient air quality impacts.
CTDEEP recommends enlisting the services of a competent environmental professional to assist you with this calculation if you do not have relevant experience.
A copy of the FAQs document can be downloaded here. You may submit comments to Jaimeson Sinclair at Jaimeson.Sinclair@ct.gov by January 10, 2020. If you have questions or need assistance in permitting your engine so that it can participate in Demand Response, please contact Kristine Davies in our Boston office at (508) 273-8600 x2701 or email@example.com.