## Randolph Electric Membership Corporation

Your Touchstone Energy® Cooperative 

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PO Box 40 Asheboro, NC 27204 879 McDowell Rd. Asheboro, NC 27205 Telephone: (336) 625-5177 Toll Free: 1-800-672-8212

November 18,2010

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 ofPortions ofthe Final Rule: National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (Docket EPA-HQ-OAR-2008-0708) Dear Administrator Jackson:
Iam writing in support ofthe National Rural Electric Cooperative Association's (NRECA) October 19, 2010, Petition for Reconsideration ofportions ofthe Final National Emission Standards for Hazardous Air Pollutants forReciprocating Internal Combustion Engines promulgated onAugust 20, 2010, (75 Fed. Reg. 51,570). (Docket EPA-HQ-OAR-2008-0708).
Irepresent Randolph Electric Membership Corporation, arural electric cooperative serving more than 31,000 consumer-members in Alamance, Chatham, Montgomery, Moore, and Randolph counties incentral North Carolina. The company is headquartered inAsheboro and has one district office inRobbins. Randolph EMC delivers over 500 million kWh ofelectric energy annually with an annual peak capacity of 135 MW to residential, commercial and industrial customers. Our meter density is approximately 7.5 meters per mile ofdistribution line. Our wholesale power supply portfolio ismade up of51 percent nuclear and 37 percent coal, with natural gas, hydro-electric, and other renewable resources completing the mix. Randolph EMC is currently working toward compliance with North Carolina's Senate Bill 3 (Renewable Portfolio Standards), replacing 10percent ofour future conventional generating resources with a combination ofrenewable generation and energy efficiency measures by 2018. NRECA's petition addresses restrictions contained in the final rule that prohibit the use ofsmall emergency generating units forpeak shaving programs and limits demand reduction service beginning in 2013 without the addition ofexpensive emission reduction technology on units larger than aspecified size. With the implementation ofnew, more expensive renewable resources and the reduction of energy sales associated with energy efficiency, combined with the need to invest in future baseload generation, all indicators point to much higher cost ofelectricity for our customers. Randolph EMC isconsidering every possible measure to keep electric rates affordable for our members.The Honorable Lisa Jackson 

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One ofthe most promising low-cost programs that will beused in the future to help offset the rising cost ofour resource portfolio isdemand-side management. Our system has inplace approximately 250 small, member-owned generators (mostly agricultural) with acombined capacity ofapproximately 9MW. The ability to control our aggregated system peak is a valuable tool related to distribution resource management. From areliability perspective, demand side management, or distributed generation control, is a component ofour emergency resource plan. In the event that wholesale capacity is not available oris limited, member-owned generation helps reduce our system need forresources. Financially, our distributed generation has proven tobe avaluable tool in controlling the cost ofwholesale power during hours when capacity was expensive by eliminating the need topurchase additional peaking capacity. Presently, our distributed generation program is operated inwhat could be best described as amaintenance mode. Member-owned generation is operated less than 20 hours per year inorder tomaintain their ready status, asthe value ofpeaking capacity has been relatively affordable. This will not be the case inthe near future. Beginning in2012, wholesale contracts indicate that the price forpeaking resources will againjustify the use ofload management during peak periods. With the continued focus on carbon fuels, such as coal, and the anticipated increase inthe use of electricity as aclean, environmentally friendly alternative energy source for consumer goods like electric vehicles, peaking capacity will be an issue in the future. The use ofload management using customer-owned generation is one affordable alternative that will help Randolph Electric Membership Corporation maintain areliable, affordable supply of electricity to our members.
Iurge the agency to reconsider these restrictions onpeak shaving and demand reduction contained inthe final rules and to amend the rules so as not to diminish the value ofthese programs to our consumer-owners. Ifyou have additional questions or would like further information regarding demand side management atRandolph Electric Membership Corporation please contact: Fred Smith, Manager ofCommunications and Business Relations, Randolph Electric Membership Corporation, P.O. Box 40, Asheboro, NC, 27204, fred.smith@randolphemc.com. Sincerely, 

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Executive Vice President and General Manager

cc: Robert Wayland Melanie King Kevin Bromberg, SBA