When Does Your New Generator Trigger a Permit?: A Practical Guide
You’ve decided you need a new generator at your industrial facility, but do you need to obtain an air construction permit before installation? It depends on where you are putting it. Here is a simple 3-step guide:
Step 1: Determine Your Generator's Use
The first step is to decide if the generator will be for emergency or non-emergency use. Emergencies include city power outage, natural disaster, or transmission grid failure. If grid power is available and the generator is run for economic benefit, convenience, or planning, it is not emergency operation. Emergency use is allowed for 100 hr/yr for testing/maintenance and unlimited operation in an actual emergency (per generator). You cannot use an emergency engine for peaking shaving. Permits for emergency generators are either not needed or easy to obtain.
Step 2: Determine Air Quality
The next step is to determine what the air quality is in your project location. If the area is not in attainment with all National Ambient Air Quality Standards (NAAQS), then local rules dictate controls and limit for even emergency generators.
Step 3: Determine Your Generator's PTE
Finally, determine your generator’s potential to emit (PTE) including all equipment in the construction project. If you need a limit to lower the PTE, then a permit is needed. If the project PTE exceeds the state construction permit thresholds, you need a permit.
In an attainment area:
If the generator is for emergency uses only and the entire project is just the emergency generator, then some states like Kansas require a simple permit before installation but other states like Missouri don’t.
If the generator is not for emergency only use and the entire project is the generator, then a simple construction permit is usually required based on unlimited PTE.
In a non-attainment area:
Each area is allowed to set their own rules, so each generator (emergency or non- emergency) needs to be analyzed.
If the non-emergency generator is part of a larger project, then the need for a construction permit depends on the total project potential to emit and if the location is in attainment or non-attainment.
Need help sorting it all out? Call your TBS air permitting and compliance experts for a quick review of your generator’s permitting needs!
