PO 2474 Winter Park, FL 32790 407. 421.7189 www.mgisys.com June 2 4 , 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:

H ealthcare facilities ha ve 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 incl ement 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

unreliab ility 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 sha ving 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 black out, 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 provid ed 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