# CROWN POINTE

Rob Lyngstad Crown Point Properties 4334 18thAve SW

Ste 103 Fargo, ND58103

November 4, 2010 The Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200Pennsylvania Ave., NW Washington, D.C. 20460 

## 2010DEC 10 AM6 : 03 i .-"L 

## EX=,OT:1+'c :

Re: Petition for Reconsideration of Portions of the Final Rule: National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines Dear Administrator Jackson: I am writing in support ofthe National Rural Electric Cooperative Association's

. (NRECA) October 14, 2010, Petition for Reconsideration ofportions ofthe Final National Emission. Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated on August 20, 2010, (75 Fed. Reg . 57,570) . Crown Point Properties is a member-owner of Cass CountyElectric Cooperative Inc. (CCEC) and is currently participating in its electric-load management programby using our stationary engine generator. The engine generator provides electric power to our facility during times of peak load conditions. In the past'severai years, the total hours of operation logged on the generator for this programhas not exceeded 100 hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100 hours annually for non-emergency situations, why should it make any difference howa business chooses to operate its generator within that 100hour limitation? In otherwords, why are there restrictions within those 100 hours of non-emergency use for peak shaving? The option to use my generator as part of a peak shaving programon a limited basis is important to me andhelps my cooperative operate its distribution,systemmost effectively. It seems to me thatthis small change to your rules would make the rules more reasonable without sacrificing air quality. Crown Point Pr©per)ies supports NRECA's petition to remove therestrictions in use of emergency stationary,engine generators as they pertainto use for peak shaving. Since the EPA has determined that 100hours of non-emergency use of a stationary engine generator poses little health risk or environmental harmabove that already contemplated

4334 - 18th Ave SW

- Suite 103 " Fargo, ND58103 " . (701) 232-5767 " FAX (701) 232-5795The Honorable Lisa Jackson

November 4, 2010 Page 2 in the rule, I believe it should not make any difference under what conditions the unit is operated within that the 100 hours ofallowable non-emergency operation In conclusion, Crown Point Properties respectfully requests the EPA reconsiders its proposed rule for spark ignition (SI) engines. Assuming the agency recognizes the common-sense logic presented in this letter with regard to the proposed SI rules, and the proposed changes put forth by NRECA, we also urge the agency to apply that same logic to the current RICE rules so as to make the final NESHAP rule consistent and uniform throughout all stationary engine generators powered by liquid fossil-fuels. Crown Point Properties respectfully requests consideration ofits request and proposed changes, and thanks the EPAin advance for the same. Thank you for your prompt attention and I look forward to your response.



### ayland, EPA Melanie King, EPA Kevin Bromberg, SBA