Skip to Content
Writing board

4 Steps to Upgrade Your Generator for Use in Demand Response

April 6, 2017

Enel X has a long history of working closely with the United States Environmental Protection Agency (EPA) to protect the use of backup generators in emergency demand response (DR) programs—to help safeguard the grid from brownouts and blackouts and to enable businesses to capitalize on demand response. Regrettably, in May 2016 the EPA began enforcing the stricter engine emissions regulations set forth in the revised National Emission Standards for Hazardous Air Pollutants (NESHAP), forcing thousands of generators out of DR programs and businesses to risk losing millions in potential DR payments.


The good news is that some generators can be upgraded to meet the EPA’s new requirements, and given how strong DR markets are right now, the ROI on these upgrade projects make the effort worthwhile. Our four-step process provides an overview of what’s involved from start to finish.


Step 1: Determine Whether Your Diesel Generator is Compliant

Not all non-compliant generators can be upgraded, and some generators don’t need to be upgraded to be compliant. So, as a first step, we’ll want to figure out which compliance category your generator falls into.


Compliance standards can be pretty complex, and NESHAP is no different. But to get you started, if you can answer “yes” to these two questions about your diesel generator’s engine, chances are quite good that it is not compliant but can be upgraded.

  • Is the generator engine larger than 225 kW or 300 hp?
  • Did you order it (or was it manufactured) before April 1, 2006?


If you have a natural gas generator, or answered “no” to any of the above, get in touch and we’ll talk it through.


Step 2: Define the Project Scope of Work

Once you’ve determined that your generator engine is upgradable, typically you will need to install a diesel oxidation catalyst (DOC) to reduce carbon emissions by at least 70%. Additionally, you’ll need a monitoring system on the DOC, crankcase ventilation, and will need to complete some stack testing and reporting. 


Some cities, counties, and states have their own air regulations, and you will need to comply with those if they are more rigid than the EPA’s air regulations.


Step 3: Gather Project Cost Estimates

There are many vendors that can upgrade your generator. We are vendor-agnostic, and can help you gather and review project cost estimates to make sure everything that’s needed for compliance has been included. 


The cost to upgrade your generator will depend on variables at your site. For example, you’ll need to ask:

  • How accessible is your generator?
  • Are additional structural supports necessary for the DOC?
  • Will installation need to occur during off hours?


Depending on the answers to these and other questions, project costs range from $40K to $80K per engine. 


Then, based on the kW loaded on your generator and the DR programs available in your area, we’ll prepare a DR earnings estimate so you can consider the project ROI.


Don’t have $40K to $80K to commit? No problem. Enel X offers project financing so you can upgrade your generators with no upfront cost.  


Step 4: Complete the Upgrade Project, Reduce your Carbon Footprint, and Start Earning!

A generator upgrade project can take anywhere from three to six months, beginning with gathering cost estimates and continuing through to final installation and testing. The actual on-site work typically takes only a few days, but the installation needs to be fully complete prior to the start of the DR program season so you can start earning right away.


Whether you’re wondering if your generator is compliant for DR use or if an upgrade project makes sense for your business, our experts are standing by to help you navigate the compliance landscape. Schedule a call today and get answers you need.