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Schatz Holdings - Petro Carwash 4510 19thAve S Fargo, ND58103

November 4, 2010 

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The Honorable Lisa Jackson Administrator United States Enviromnental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pciuisylvania Ave., NVV Washington, D.C. 20460 ~, : Or InL 

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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 Cooperative Association's (NRECA) October 19, 2010, Petition for Reconsideration ofportions ofthe Final National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated on August 20, 2010, (75 Fed. Reg. 51,570)
. Schatz Holdings - Petro Carwash is a member-owner ofCass County Electric Cooperative Inc. (CCEC) and is currently participating in its electric load management programby using our stationary engine generator . The engine generator provides electric power to our facility during times ofpeak load conditions. In the past several years, the total hours ofoperation logged on the generator for this programhas not exceeded 100 hours. Inasmuch as the Environmental ProtectionAgency (EPA) rules allowan emergency use engine generator to operate upto 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? 1n 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 programon a limited basis is important to me and helps my cooperative operate its distribution systemmost effectively. It seems to me that this small change to your rules would make the rules more reasonablewithout sacrificing air quality. Schatz Holdings - Petro Carwash supports NRECA's petition to remove the restrictions in use ofemergency stationary engine generators as they pertain to use for peak shaving. Since the EPA has determined that 100 hours ofnon-emergency use of a stationary engine generator poses little health risk or environmental harmabove that alreadyThe Honorable Lisa Jackson

November 4, 2010 Page 2 contemplated in the rule, I believe it should not make any difference under what conditions the unit is operated within that the 100 hours ofallowable non-emergency operation In conclusion, Schatz Holdings - Petro Carwash respectfully requests the EPA reconsiders its proposed rule for spark ignition (SI) engines. Assuming the agency recognizes thecommon-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 uniformthroughout all stationary engine generators powered by liquid fossil-fuels. Schatz Holdings - Petro Carwash respectfully requests consideration ofits request and proposed changes, and thanks the EPAin advance for the same. Thank you for your prompt attention and I look forward to your response.

cc: Robert Wayland, EPA Melanie King, EPA Kevin Bromberg, SBA4 9i