# Rr_ Bob Nelson County 20 Storage 4001 32nd St N West Fargo, ND58078 

## 2010 DEC I 0 AM6~ 05

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

.C. 20460 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 amwriting in support of the National Rural Electric Cooperative Association's (NRECA) October 19, 2010, Petition for Reconsideration of portions ofthe Final National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated on August 20, 2010, (75 Fed. Reg . 5I,S70) . County 20 Storage is a member-owner ofCass County Electric 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 several years, the total hours of operation logged on the generator forthis programhas not exceeded 100hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100hours annually for non-emergency situations, why should it make any difference how a business chooses to operate its generator within that 100 hour limitation? In otherwords, why are there restrictions withinthose 100hours of non-emergency use for peak shaving? Theoption to use my generator as part ofa peak shaving programon a limited basis is important to me and helps my cooperative operate its distribution systemmost effectively. It seems to me that this small change to your rules would make the rules more reasonable without sacrificing air quality. County 20Storage supports NRECA's petition to remove the restrictions in use of emergency stationary engine generators as they pertain to use for peak shaving. Since the EPAhas determined that 100hours of non-emergency use ofa stationary engine generator poses little health risk or environmental harm above that already contemplatedThe Honorable LisaJackson November 4, 2010 Page 2 inthe rule, I believe it should not make any differenceunder what conditions the unit is operated within that the 100hours ofallowable non-emergency operation In conclusion, County 20 Storage respectfully requests the EPA reconsiders its proposed rule for spark ignition (SI) engines. Assuming the agency recognizes the common-sense logic presented in this letterwithregard 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. County 20 Storage respectfully requests consideration of its 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. Sincerely,

cc: Robert Wayland, EPA Melanie King, EPA Kevin Bromberg, SBAI 

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