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November 12, 2010 

121 SE First Street I PO Box 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) 

1200 Pennsylvania Ave., NW 

Washington, D .C . 20460 

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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 

Dear Administrator Jackson : 

I am writing in support of the National Rural Electric Cooperative Association'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 on August 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 and western Minnesota . As not-for-profit rural electric 

cooperatives owned by those we 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, each with 

the goal of delivering affordable 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 them during 

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 generation sources face higher peak demand loading . 

The most significant problem is the amount hours per year these engines will be 

allowed to operate under the new rules . Successful peak shaving cannot and should 

not be limited to a certain number of hours per year. Local electric consumption 

patterns determine when and how long peak demand occurs. Flexibility is key, and we 

have already heard from some 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 . We also 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 from the 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 NRECA petition . 

Sincerely, 

Jeffrey L . Nelson 

General Manager 

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c: Robert Wayland 

Melanie King 

Kevin Bromberg, SBA 
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