We investigated the implications of behind-the-meter (BTM) generation participating in demand response (DR) programs. Specifically, we evaluated the impacts of NOx emissions from BTM generators enrolled in the New York Independent System Operator (NYISO)'s reliability-based DR programs. Through analyzing the DR program enrollment data, DR event records, ozone air quality monitoring data, and emission characteristics of the generators, we found that the emissions from BTM generators very likely contribute to exceedingly high ozone concentrations in the Northeast Corridor region, and very likely account for a substantial fraction of total NOx emissions from electricity generation. In addition, a companion study showed that the emissions from BTM generators could also form near-source particulate matter (PM) hotspots. The important policy implications are that the absence of up-to-date regulations on BTM generators may offset the current efforts to reduce the emissions from peaking power plants, and that there is a need to quantify the environmental impacts of DR programs in designing sound policies related to demand-side resources. Furthermore, we proposed the concept of "Green" DR resources, referring to those that not only provide power systems reliability services, but also have verifiable environmental benefits or minimal negative environmental impacts. We argue that Green DR resources that are able to maintain resource adequacy and reduce emissions at the same time are key to achieving the cobenefits of power system reliability and protecting public health during periods with peak electricity demand.
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