R r_ 

Bob Nelson 

County 20 Storage 

4001 32nd St N 

West Fargo, ND 58078 

2010 DEC I 0 AM 6~ 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 am writing in support of the National Rural Electric Cooperative Association's 

(NRECA) October 19, 2010, Petition for Reconsideration of portions of the 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 of Cass County Electric Cooperative Inc. (CCEC) 

and is currently participating in its electric load management program by 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 for this program has not exceeded 100 hours. 

Inasmuch as the Environmental Protection Agency (EPA) rules allow an emergency use 

engine generator to operate up to 100 hours 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 other words, 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 program on a limited basis is important to me and helps my cooperative operate 

its distribution system most effectively. It seems to me that this small change to your 

rules would make the rules more reasonable without sacrificing air quality . 

County 20 Storage 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 

EPA has determined that 100 hours of non-emergency use of a stationary engine 

generator poses little health risk or environmental harm above that already contemplated 
The 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 of allowable 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 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 . 

County 20 Storage respectfully requests consideration of its request and proposed 

changes, and thanks the EPA in 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, SBA 
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