Guy Goschen

Hornbachers 1532 32nd Ave S Fargo, ND 58103
November 4, 2010 The Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios t3uiiding (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, 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) . Hornbaehers 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 of operation logged on the generator for this programhas not exceeded 100hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100hours 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, whyare there restrictions within those 100hours of non-emergency use for peak shaving? Theoption 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 reasonable without sacrificing air quality. Hornbachers supports NRECA's petition to remove the restrictions in useofemergency stationary engine generators as they pertain to use for peak shaving. Since the EPAhas determined that 100hours of non-emergency use ofa stationary engine generator poses little health risk or environmental harmabovethat already contemplated in the rule, IThe Honorable Lisa Jackson

November 4, 2010 Page 2 believe it should not make any difference under what conditions the unit is operated within that the 100hours ofallowable non-emergency operation In conclusion, Hornbachers respectfully requests the EPAreconsiders 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 S1 rules, and the proposed changes put forth by NREGA, 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. Hornbachers respectfully requests consideration ofits request and proposed changes, and thanks the EPAin advancefor the same. Thank you for your prompt attention and I look forward to your response. Sincerely, Guy Goschen cc: Robert Wayland, EPA Melanie King, EPA Kevin Bromberg, SBAr~ . +,y,

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