The Dark Side of DG: Addressing the Environmental Impacts of Dirty Distributed Generation
33 Pages Posted: 18 Mar 2016 Last revised: 1 Oct 2016
Date Written: March 16, 2016
Distributed generation (“DG”) is playing an increasingly important role in the United States electricity sector. That growth is a function both of DG’s many economic and reliability benefits as well as the numerous state and federal policies that support DG. The environmental and human health impacts of DG, however, are less clear. Although some forms of DG emit little or no pollution, some fossil-fuel-fired types of DG — and diesel engines in particular — can emit significant quantities of conventional pollutants, such as nitrogen dioxide and particulate matter, as well as greenhouse gases. The health and environmental impacts of these emissions is often exacerbated by several unique characteristics of fossil-fuel-fired DG. The various federal, state, and local regulations applicable to fossil-fuel-fired DG help address these impacts, but only partially. These regulations generally address only the emissions from an individual DG unit, thereby leaving open the possibility that a high concentration of DG in a small area could have significant adverse consequences.
Although the economic and reliability benefits of DG have received considerable attention in the legal literature, its health and environmental implications have gone comparatively unstudied. This Essay fills that gap by examining of how current regulations address the health and environmental effects of increased fossil-fuel-fired DG. In addition, the Essay identifies a series of options that policymakers ought to consider as they contemplate how best to address the potential impacts of a significant increase in fossil-fuel-fired DG.
Keywords: Environmental law, distributed generation, REV, public utilities, demand response
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