CARISCH, INC.

681 E LAKE ST. #262

WAYZATA, MN 55391

TEL: 952-476-7280

FAX: 952-697-1912

CELL: 612-812-5275

e-mail: george@carischinc.com

December 6, 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. 

51,570).

Arby's 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.
The Honorable Lisa Jackson

November 23, 2010

Page 2

Arby's 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 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, Arby's 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.

Arby's 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 1 look forward to your response.

Sincerely,

George Carisch

Carisch, Inc. DBA Arby’s

cc: Robert Wayland, EPA

Melanie King, EPA

Kevin Bromberg, SBA