## CARISCH, INC. 681 E LAKE ST. #262 WAYZATA, MN 55391 TEL: 952 -476 - 7280 FA X: 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 , N W Wa shington, D.C. 20460 Re: Petition for Reconsideration of Portions of the Final Rule: National Emission Standards for Hazardous Ai r 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 Nat ional Emission Standards for Hazardous A ir 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 Elect ric Cooperative Inc. (CCEC) and is currently participat ing 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 th e past several years, the total hours of operation logged on the g enerator fo r this program has not exceeded 100 hours. Inasmuch as the Environmental Protect ion Agency (EPA) rules allow an emergency use engine generator to operate u p to 100 hours annually for non emergency situations, why should it make any difference h ow a business chooses to operate its generator within that 100 h our limitation? In other words, wh y are there restrictions within those 100 hours of non

- e mergency use for peak shaving? The option to use my generator as part of a peak shaving program on a l imited 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

- emerg ency use of a stationary engine generator poses little health risk or enviro nmental 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 e mergency operat ion. In conclusion, Arby's respectfully requests the EP A reconsiders its proposed rule for spark ignition (SI) engines. Assuming t he agency recognizes the common sense logic presented in this letter with regard to the proposed SI rules, and the proposed c hanges put forth by NRECA, we als o urge the agency to apply that same logic to the current RICE rules so a s to make the final NESHAP rule consistent and uniform throughout all stationary engine generators powered by liquid fossil

-fuels. Arby's respectfull y 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 Wa yland, EPA Melanie King, EPA Kevin Bromberg, SBA