Donaldson, Robert (DEP) 

From: 

Sent: 

To: 

Subject: 

David Brewster [DBrewster@enernoc.com] 

Wednesday, June 30, 2004 4:22 PM 

Donaldson, Robert (DEP) 

EnerNOC comments 

ments_MA DEP.pdf 

Bob, 

Attached please fin d comments from EnerNOC, Inc . regardin g th e proposed amendments t o 

310 CMR 7.00 and 310 CMR 70.00. 

Please le t me know i f I can provid e any othe r informatio n tha t would be o f assistance . 

Thank you i n advance fo r your consideratio n o f these comments. 

Best regards, 

David 

David Brewster 

EnerNOC, Inc . 

One Faneui l Hall , 3r d Floo r 

Boston, MA 02109 

617-224-9902 (Office ) 

617-794-6227 (Cell ) 

DBrewster@EnerNOC.com 

www.EnerNOC.com 

1 
ENERNOC 

Robert Donaldson, Associate Director 

Department of Environmental Protection 

Business Compliance Division 

Bureau of Waste Prevention 

One Winter Street, 8th Floor 

Boston, MA 02108 

June 30,2004 

Dear Mr. Donaldson, 

Thank you for allowing EnerNOC, Inc. to provide input into the Department of Environmental 

Protection's (DEP) proposed amendments to 310 CMR 7.00 and 310 CMR 70.00. EnerNOC is a 

privately-funded company that helps energy users manage their energy consumption and reduce 

their demand for electricity during localized and system-wide capacity deficiency emergencies to 

create a more robust and reliable electricity grid - a solution called Demand Response. 

EnerNOC is active in areas where the electricity grid is most strained, including Northeast 

Massachusetts/Boston ("NEMA/Boston"), Southwest Connecticut (SWCT), New York City, and 

Long Island. 

EnerNOC strongly supports the DEP's proposed amendment to the definition of "Emergency" as 

it pertains to the operation of new and existing emergency engines. More specifically, we 

applaud the DEP's efforts to allow the operation of emergency engines as "last line of defense" 

demand response assets when the imminent threat of a power outage is likely. 

While the base of installed generating capacity in New England exceeds the region's peak 

demand, our electricity grid is in dire need of help. Capacity deficiency problems are most acute 

in the two constrained zones of SWCT and NEMA/Boston, areas with high demand for 

electricity and insufficient access to regional supplies. The strain on the electricity grid in these 

zones will only worsen as demand continues to steadily increase and suitable sites for new 

generation and transmission capacity become more difficult to find. 

Demand response exists today as one of the only reliable and quick-to-service solutions to the 

capacity shortfalls in constrained zones. Through ISO New England (ISO-NE) and utility-based 

demand response programs, energy users can shed load from the grid when the imminent threat 

of a power outage is likely. They can do so either by reducing their demand (i.e., shutting off 

lights, air conditioners, or other non-critical loads) or by proactively generating power to meet 

their own needs (i.e., running emergency generators), as they would do anyway if and when the 

grid were to fail or to impose unacceptable voltage reductions. 

Allowing emergency engines to operate when the imminent threat of a power outage is likely is 

important because these resources have the potential to prevent power failures, which are 

injurious for health and safety and the environment. When the grid fails, every emergency 

generator that has an automatic transfer switch fires up (or attempts to), and others that do not 

automatically start up are manually started by their owners/operators. This existing fleet 

EnerNOC, Inc. | One Faneuil Hall, 3r d Floor | Boston, MA 02109 | 617-224-9900 
includes many poorly maintained, non-permitted generators that burn dirty fuels. It can take a 

long time, even days, to restore conditions to normal operating levels, so these emergency 

generators will likely run for extended periods of time after a power failure, causing severe 

degradation in air quality. In addition, public health and safety are directly affected by 

blackouts, as people can be stuck in elevators, traffic lights can malfunction, emergency response 

systems can become overloaded, and failures can occur at mission critical environmental 

facilities such as wastewater treatment plants. For instance, last August in New York City, 

approximately 490 million gallons of untreated sewage were dumped into the city's rivers 

because of the power failure. 

While diesel generators are not the cleanest source of generation, a recent study conducted for 

the EPA by Synapse Energy, a research and consulting firm that specializes in environmental 

and energy topics, shows that air emissions would be reduced in New England if Demand 

Response (including the use of diesel fired generators) is included in the resource mix (Synapse 

Energy Economics Study for the US EPA, August 2003). It is also important to note that all 

diesel generators participating in ISO-NE's 30-Minute Real-Time Demand Response Program 

are required to be permitted and to use only ultra-low sulfur diesel fuel. EnerNOC facilitates this 

shift to cleaner fuel consumption to help its customers reduce their emissions. 

Also, EnerNOC has found that when we gain the attention of energy users by providing revenue 

for participating in Demand Response, such users typically explore and select further energy 

conservation opportunities. Further, this link between financial incentives and conservation acts 

as a powerful regulatory tool since it may serve as a market-based incentive for energy 

consumers to invest in new technologies designed to significantly reduce their emissions in the 

future. 

While EnerNOC supports the DEP's proposed amendment to the definition of "Emergency," the 

proposed language as written is silent on previously approved emergency engines (i.e., those 

engines with existing air plan approvals that are not regulated under performance standards 

contained in 310 CMR 7.02 (8)(i) and 310 CMR 7.03(10)). EnerNOC recommends that the DEP 

treat ALL emergency engines consistently by considering regulatory language that would also 

allow previously approved emergency engines to operate when the imminent threat of a power 

outage is likely. 

If you have any questions or require additional information, please do not hesitate to contact me 

at (617) 224-9902. Thank you in advance for your consideration of our comments. 

Sincerely, 

David B. Brewster 

President & Chief Operating Officer 

EnerNOC, Inc. 

EnerNOC, Inc. | One Faneuil Hall, 3r d Floor | Boston, MA 02109 | 617-224-9900