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NESHAP ZZZZ Engine Rules at an Airport

NESHAP ZZZZ Engine Rules at an Airport

(OP)
Most airports are required by the FAA to have emergency generators operating during periods of low visibility in the event that utility power would be lost so that runway lighting will not go down. The new engine rules (NESHAP ZZZZ) specify that "emergency" generators can comply with the rules using work practice standards (rather than having numerical emission limits). The problem is that ZZZZ defines "emergency" as periods when utility power is lost. Generally utility power will NOT be lost in the situation described above. Therefore one could consider this to be a "non-emergency" engine. Has anyone obtained an applicability determination from EPA on if such a use is considered emergency or non-emergency?

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