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4TwchsWraFmu'laoPxrar .c ~R t Rd rlr, November 12, 2010 121 SE First Street I POBox 227 Telephone: (605) 256-4536 Madison, SD 57042-0227 Fax: (605; 256-8058

The Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200Pennsylvania Ave., NW Washington, D.C. 20460 N 7~ c C > r _ O - rTi ` .' N FTI (Z~ W ' - a

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Re: Petition for Reconsideration of Portions of the Final Rule: National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines DearAdministrator Jackson: I am writing in support ofthe National Rural Electric CooperativeAssociation's (NRECA) October 19, 2020, Petition for Reconsideration of portions of the Final National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated onAugust 20, 2010, (75 Fed. Reg. 51,570) . East River Electric Power Cooperative is the wholesale power supplier for 25 member distribution systems that in turn provide electric service to approximately 92,000 retail accounts in eastern South Dakota andwestern Minnesota. As not-for-profit rural electric cooperatives owned by thosewe serve, we are acutely aware of the hardship caused by increasing costs for electricity. As such, we collectively have developed and implemented a wide variety of energy efficiency and peak shaving programs, eachwith the goal ofdeliveringaffordable and reliable electric service. The reciprocating engines covered by the recent EPA rules provide vital emergency back-up power during electric outages. These same engines, owned by our customers, are also used in partnership with the cooperatives' peak shaving programs. These generators can save as much as 30%on retail electric costs by operating themduring periods of peak electrical demand. This is truly a win-win for the customer, the utility, and the overall electrical grid.Honorable Lisa Jackson -2- November 12, 2010

These rules change a win-win into a lose-lose. The customer with generation is faced with expensive retro-fit costs or an immediate rate increase caused by not being able to operate the generators enough hours for the peak shaving programs. The utility loses an important "smart grid asset" by losing dispatchable generation and the grid and existing generationsources face higherpeak demand loading. The most significant problem is the amount hours per year these engines will be allowed to operate under the newrules. Successful peak shaving cannot and should not be limited to a certain number of hours per year. Local electric consumption patterns determinewhen and howlong peak demand occurs. Flexibility is key, and we have already heard fromsome our members that the retro-fit costs are too high to allow continued participation in the peak shaving program . . While we ultimately would like to see the rules modified to permit greater flexibility, we support NRECA's petition regarding removal of the restriction on the use of these engines for peak shaving in the 100 hours of non-emergency use operation as allowed in the rules. Wealso support sensible, practical steps in protecting public heath and the environment, but these rules, when implemented, will raise costs for retail customers and remove an important "Smart Grid" asset fromthe electric grid. Please contract me at 605-256-4536 with any questions or if additional information is needed. Thank you for your consideration and we sincerely hope your response supports the NRECApetition. Sincerely, Jeffrey L. Nelson General Manager JN/jg c: RobertWayland Melanie King Kevin Bromberg, SBAQ W O r ca ~ IV ~

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