November 8 , 2010

The Honorable L isa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania Ave., NW Washington, D.C. 20460 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 fo r 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 ). Allamakee

- Clay

ton Electric Cooperative (ACEC) is a m ember

- owned electric distribution cooperative located in northeast Iowa. We serve approximately 9748 member

- consumers and are about 95% rural residential or agricultural farm operations in consumer makeup. Farms are typicall y grain and/or livestock based operations, including a significant dairy

and swine industry

which is very

dependent on affordable and reliable electric service. We have only

recently become aware of the proposed RI CE NESHAP rules and the potential impact of these rules on our cooperative member

- consumers. As a distribution cooperative without our own generation facilities, we have had no practical reason to track and review the many and varied rulemaking activities under the Clean Air Act. Lacking an y outreach from the EPA, we have b een taken off

- guard b y the proposed rules and the potential adverse impact that such changes would have on what has been heretofore, a very

successful and practical peak shaving program. NRECA’s petition addresses restrictions contained in the final rule that prohibit the use of small emergency

generating units for peak shaving programs. ACEC has offered a variet y of load management programs for man y years, including a Peak Alert Program which allows member

- consumers to utilize their emergency generators f

or peak shavingpurposes. Currentl y we have 20 such accounts which help the cooperative to realize

approximate 1655 kW in demand reduction during times of sy stem peak demand. While the resultant savings are beneficial to the cooperative membership as a whole, the real measure of success is with the member

- owners of the generating units. These units have largel y been installed as emergency backup generators for livestock operations. Without these critical units, the livestock producers could suffer large financial loss due to livestock mortality

during power outages. By including these generating units in our Peak Alert Program, the owners have realized additional financial benefits from the generating units and are better able to justify the costs of wh at is in reality , a necessity for the financial safeguarding of their farm operations. ACEC’s peak shaving programs ty pically involve minimal hours of operation, and would not generall y add to the 100 annual hours of operation allowed under the rules. Co ntinuing to allow use of member

- owned generators for peak shaving programs would not, therefore, cause an y significant additional public health risks or environmental harm. Elimination of this program would, however, require procurement of additional cent ral station generation capacity as well as possible additional transmission and distribution line capacity

in order to serve the increased demand. In light of the minimal adverse environmental effects and the offsetting benefits of continuing to allow use of small emergency generating units for peak shaving programs, ACEC is requesting that the EPA reconsider the provisions of the final RI CE NESHAP rules that would otherwise restrict the operation of these units for peak shaving and demand reduction programs. Please contact me if you have an y questions or need additional information. Thank you for your careful consideration of this matter. Sincerel y,
Paul D Foxwell Executive Vice President/General Manager

cc: Robert Wayland Melanie King Kevin Bromb erg, SBA