PO 2474 Winter Park, FL 32790 407.421.7189

 www.mgisys.com

June 24, 2010

Ms. Melanie King

Energy Strategies Group

Sector Policies and Programs Division D243–01

U.S. EPA

Research Triangle Park, North Carolina 27711

Re: 40 CFR Parts 60, 1039, 1042, et al.; Standards of Performance for Stationary Compression 

Ignition and Spark Ignition Internal Combustion Engines; Proposed Rule

Docket ID No. EPA–HQ–OAR–2010–0295

Dear Ms. King:

Healthcare facilities have been severely affected by the restrictions placed on them by the

provisions of the original ruling enacted June, 2006. To exacerbate the problem there has been 

an increase in power interruptions in several areas of the country resulting from utilities not 

having the infrastructure to handle increased loads in times of inclement weather and power 

anomalies.

To mitigate the inherent dangers of these issues healthcare facilities have sought to enter into 

Demand Response agreements with their electric utilities in order to be pro-active when power 

unreliability can be reasonable predicted.

Unfortunately, power problems are going to increase, and will probably total in excess of 15 

hours during any given year in certain areas. Therefore we are respectfully requesting that the 

proposed provisions of §60.4211(f)(4) be changed to read as follows:

(4) You may operate your emergency stationary ICE up to 50 hours per year in non-emergency 

situations, but those 50 hours are counted towards the 100 hours per year provided for 

maintenance and testing. The 50 hours per year for non-emergency situations cannot be used 

for peak shaving or to generate income for a facility to supply power to an electric grid or 

otherwise supply power as part of a financial arrangement with another entity; except that 

owners and operators may operate the emergency engine for a maximum of 15 hours per year

any period of time as part of a demand response program if the regional transmission 

organization or equivalent balancing authority and transmission operator has determined there 

are emergency conditions that could lead to a potential electrical blackout, such as unusually 

low frequency, equipment overload, capacity or energy deficiency, or unacceptable voltage 

level. The engine may not be operated for more than 30 minutes prior to the time when a

period of time that the emergency condition is expected to exist occur, and then the engine 

operation must be terminated immediately after the facility is notified that the emergency 

condition is no longer imminent. The 15 hours per year of demand response operation are not

counted as part of the 50 hours of operation per year provided for non-emergency situations. 

The supply of emergency power to another entity or entities pursuant to financial arrangement 

is not limited by this paragraph (f)(4), as long as the power provided by the financial 

arrangement is limited to emergency power.
PO 2474 Winter Park, FL 32790 407.421.7189

 www.mgisys.com

We believe these changes will not detract from the intent of the proposed changes, but will in 

fact add an increased level of protection for patients and staff.

Coincidentally, we just reviewed the following publication recently published by the DOE. It 

details how diesel generators may be the least expensive, and cleanest, solution to future 

power crisis.

Backup Generators (BUGS): The Next Smart Grid Peak Resource

(http://www.netl.doe.gov/smartgrid/referenceshelf/whitepapers/BUGS_The%20Next%20Smart

%20Grid%20Peak%20Resource%20%28April%202010%29.pdf)

We would greatly appreciate consideration to this extremely important issue.

Regards,

Dan Chisholm Sr.

Copies (2)

Air and Radiation Docket and Information Center

Environmental Protection Agency

Mail code: 6102T

1200 Pennsylvania Ave., NW.,

Washington, DC 20460