9~ i 

Schatz Holdings - Petro Carwash 

4510 19th Ave S 

Fargo, ND 58103 

November 4, 2010 

2N0 DEC 10 AM 6: 04 

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 

c UT~+~ Sev ~FJ=~~ 

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 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. 51,5 70). 

Schatz Holdings - Petro Carwash is a member-owner of Cass County Electric 

Cooperative Inc. (CCEC) and is currently participating 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 the past several years, the 

total hours of operation logged on the generator for this program has not exceeded 100 

hours. 

Inasmuch as the Environmental Protection Agency (EPA) rules allow an emergency use 

engine generator to operate up to 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 program on a limited 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 . 

Schatz Holdings - Petro Carwash 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-emergency use of a stationary 

engine generator poses little health risk or environmental harm above that already 
The 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 of allowable 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 the common-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 uniform throughout all stationary engine generators powered by liquid fossil-fuels . 

Schatz Holdings - Petro Carwash respectfully requests consideration of its request and 

proposed changes, and thanks the EPA in 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, SBA 
4 

9i