C31 I W i 

June 30,2004 

Mr. Robert T. Donaldson, Associate Director 

Business Compliance Division 

Bureau of Waste Prevention 

Department of Environmental Protection 

One Winter Street, Eighth Floor 

Boston, MA 02108 

RE: Proposed Amendments to 310 CMR 7.00 and 310 CMR 70.00 

Dear Mr. Donaldson: 

Pinpoint Power appreciates the opportunity to provide input into the Massachusetts 

Department of Environmental Protection's ("DEP") proposed regulation changes for engines 

and turbines (310 CMR 7.00 and 310 CMR 70.00). Pinpoint Power develops, owns and 

manages power and demand side management assets in the Northeast. Pinpoint Power has 

been an active Demand Response Provider in the New England Power Pool since 2002. We 

applaud the DEP's efforts to proactively address both new distributed generation technology 

and at the same time the urgent need to increase the reliability of electric power supply in 

Massachusetts, particularly in the Northeast Massachusetts/Boston ("NEMA/Boston") area. 

The Independent System Operator for New England ("ISO New England" or "ISO"), the notfor-profit entity responsible for operating New England's bulk power system, has determined 

that electric load in Massachusetts could exceed the capability of existing electric generating 

and transmission resources in the region. Under certain conditions, these resources may not 

be able to supply the load without overloading the lines or causing low voltages. In 2002, the 

ISO reported that two to four times per year a portion of the region is only one step away 

from shedding 50 to 100 megawatts ("MW") of load for as many as ten hours at a time. 

Accordingly, the state needs to take immediate action to ensure the continued reliability of 

power supply in the area. A strong Massachusetts' economy and business climate depends on 

this reliability. Fortunately, the DEP's recommendation to amend the definition of 

"emergency" to allow customers' back up generators to participate in ISO New England's 30 

minute real-time demand response program (a.k.a. emergency demand response program) is 

exactly the kind of action required. 

The DEP's recommendation to amend the definition of "emergency" needs to explicitly 

include situations when ISO New England declares Action 12 under the New England Power 

Pool ("NEPOOL") Operating Procedure 4 ("OP 4") "Action During A Capacity Deficiency" 

or higher for a specified area. OP 4, Action 12, as it is referred to, is the start of brownouts 

with the next step being involuntary interruptions of load. This declaration is taken very 

1040 Great Plain Avenue 

Needham, MA 02492 

Ph: 781-453-1145 

Fax: 781-453-1 142 
Mr. Robert Donaldson 

Page 2 

June 30,2004 

seriously by the ISO. In fact, even under the extreme weather conditions which occurred 

during the summer of 2002, the ISO did not declare OP 4, Action 12. Other than on August 

15, 2003, in response to the major power failure that occurred throughout the Northeast, this 

level has rarely been declared - it is truly reserved for emergency situations. This declaration 

should not be confused with other ISO programs that are enacted for economic reasons (e.g., 

economic demand response). 

It is recommended that the DEP use language similar to the language that the Connecticut 

DEP has used in its proposed amendment to the definition of "emergency." This proposal 

has gone through the public hearing process and is expected to be enacted on January 1, 

2005. The proposed language that the Connecticut DEP has proposed in §22a-174-22(a)(4) 

that revises the definition of "emergency" is: 

"requires the operation of the emergency engine during the period of time in 

which the New England Region System Operator begins voltage reductions or 

involuntary load interruptions within the Connecticut load zone." 

This revision does not explicitly use the term OP 4, Action 12 because the DEP was 

concerned that ISO may change the terminology in the future. Thus, language was used that 

describes OP 4, Action 12. It is not until OP 4, Action 12 that the ISO can implement voltage 

reductions. OP 4, Action 12, as approved by the NEPOOL Participants Committee on June 

26, 2003, is: 

"Implement a voltage reduction of five percent (5%) of normal operating voltage 

requiring more than 10 minutes to implement. Interrupt Real-Time Demand 

Response - 30 Minutes or Less Notification (that requires a voltage reduction to be 

implemented)." 

I do not believe the language that the DEP proposes in its revisions to 310 CMR 7.00 is 

adequate. Specifically, the proposed language: 

"Emergency shall also mean when the imminent threat of a power outage is likely 

due to failure of the electrical supply or when capacity deficiencies result in a 

deviation of voltage from the electrical supplier to the premises of three percent (3%) 

above or five percent (5%) below standard voltage." 

should be replaced with the following language that combines the Massachusetts DEP's 

proposed language along with what the Connecticut DEP is using: 

"Emergency shall also mean when the imminent threat of a power outage is likely 

due to failure of the electrical supply, such as when the operation of the emergency 

engine is required during the period of time in which the New England Region 

System Operator begins voltage reductions or involuntary load interruptions within 

the Massachusetts load zone." 

The modified definition of "emergency" should apply to all new and existing sources, 

whether they are permitted by rule or by an air plan approval. All emergency engines should 

be treated consistently. Thus, the existing air regulations for emergency engines as regulated 

by permit by rule need to be amended so that the definition of "emergency" also applies to 
Mr. Robert Donaldson 

Page 3 

June 30,2004 

existing emergency engines located at facilities with existing air plan approvals. Thus, the 

modified definition of "emergency" will be consistent; otherwise, the DEP will have to 

modify every air plan approval that has been issued for emergency engines. 

We are also aware of a report prepared by Synapse Energy Economics, Inc. for the 

Environmental Protection Agency ("EPA") entitled "Results of Demand Response Emissions 

Modeling" by Geoff Keith, Bruce Biewald, David White and Mike Drunsic dated August, 

2003 and revised September 4, 2003, assessing the impacts of demand response ("DR") in 

New England using an electric system dispatch model.1 As the draft report states, "when the 

DR resource is used to meet reserve requirements, the result is more efficient unit 

commitment, reduced operation of oil- and gas-fired steam units and increased operation of 

combined-cycle units in New England." Even assuming all DR is from diesels, the report 

showed a net benefit in air quality. Thus, by changing the definition of emergency, more DR 

resources will provide the necessary reserve capability and regional air quality should 

actually improve. 

The DEP is currently proposing that an alternative to certification be available via an 

application under the 310 CMR 7.02 plan approval process for a limited number of facilities 

including: peaking power units, load shaving units, units in energy assistance programs, 

mechanical power units to run pumps, unites in natural gas pipeline service, and units using 

landfill digesters or biogas. The DEP should not limit the option of obtaining an air plan 

approval to a limited number of facility types. This option should be available to all source 

types. 

Finally, according to the suppliers of ultra-low sulfur diesel fuel, due to testing limitations, 

they cannot guarantee the sulfur content of the fuel to 0.015% or 15 ppm sulfur. A more 

realistic limit is 0.003% or 30 ppm sulfur which is what the Connecticut DEP has proposed in 

its regulations. 

Thank you for allowing Pinpoint Power to provide these comments. If you have any 

questions or require additional information, please do not hesitate to contact me at 617-699-

3756. 

Very truly yours, 

PINPOINT POWER 

Thomas E. Atkins 

President 

1

 A hypothetical near-term year in New England using projected 2006 fuel prices and loads was 

modeled. The modeling included 500 MW of DR capability: 60 percent load response and 40 percent 

generation. The emissions impacts when DR is used for reserves results in significant decreases of 

criteria pollutant emissions, even when it is assumed that the DR used to meet reserves is all diesel 

(e.g., summer air impacts include: oxides of nitrogen decreases 23 tons, sulfur dioxide decreases 216 

tons, carbon dioxide decreases 31,400 tons, particulate matter 2.5 microns or less decreases 12.5 tons, 

particulate matter decreases 21.2 tons and mercury decreases 0.29 tons).