Cliff: De-rate calculator

Load a known site

Public filings · primary-cited

Site

State

Interconnection product offered

Load and generator fleet

IT load at POI (MW)

Generator fleet nameplate (MW)

Aggregate backup gen across the campus, including N+1.

Source type

Auto-filled as stationary CI RICE because that is the usual backup-generator stack.

EPA tier

Fuel

Expected runtime hours

Curtailment p50 (hrs/yr)

Median expected. e.g., 6 events × 6 hrs.

Curtailment p90 (hrs/yr)

Worst-case stress test.

Maintenance + testing (hrs/yr)

Expected true outages (hrs/yr)

State emergency definition

Treat curtailment as 'emergency' under Virginia air permit?

Post-APG-578, Virginia DEQ conditionally treats utility outages noticed within 14 days as emergencies. Pre-memo, only acute outages qualified.

CAA permitting defaults

PTE basis

Default uses the state permit cap as the enforceable limit. The synthetic-minor option computes a tighter cap where needed.

Source boundary

Aggregation can change the stationary-source boundary for NSR and Title V.

Live result

No peak de-rate

Nameplate

500 MW

Effective MW (peak)

500 MW

Air permit covers expected curtailment

Binding constraint

RICE NESHAP non-emergency budget (100 hrs/yr)

The federal RICE NESHAP non-emergency cap is the closer ceiling. State permit headroom is larger but is not the binding rule.

CAA class

Title V major-source screen

Triggered

Compliance

$7,000/MW-yr

Net value

$173,000/MW-yr

CAISO FRP revenue (median scenario)

Suppressed

FRP is a CAISO-only product. Sites outside CAISO see no FRP revenue. The same logic applies to the analogous products in PJM (Regulation + Synchronized Reserves), ERCOT (ERS / CLR / PCLR), MISO (RCP), and NYISO/ISO-NE — those will be added as separate revenue inputs.

Directional model. Not legal advice. The full report below cites every rule on every line.

Hour budgets, Title V detail, citations.

Hour budgets, Title V detail, citations.