Alaska Power Association 

703 West Tudor Road, Suite 200 

Anchorage, Alaska 99503-6650 

907-561-6103 

Fax: 907-561-5547 

www.alaskapower.org 

December 15, 2010 

Administrator Lisa P. Jackson 

Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 2046o 

Subject: National Emission Standards for Hazardous Air Pollutants for 

Compression Ignition Reciprocating Internal Combustion Engines 

40 CFR Part 63, Subpart ZZZZ; Docket #OAR-2oo2-0059 

Dear Administrator Jackson: 

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Please accept this letter of petition and consider the unintended consequences of the final ruling 

on 40 CFR Part 63, Subpart ZZZZ, published in the Federal Register on March 3, 2oio. The 

establishment of new numerical emission limits for carbon monoxide (CO) emitted from 

existing stationary combustion ignition (CI) reciprocating internal combustion engines (RICE) 

located in area sources is creating a significant financial burden on many rural Alaska utilities. 

This letter respectfully requests that the Environmental Protection Agency (EPA) reconsider its 

definition of rural Alaska that currently excludes many rural communities accessed by the 

Federal Aid Highway System (FAHS) . 

Alaska Power Association is the statewide trade association for the electric utilities that supply 

power to .communities from Barrow to Adak and down the Inside Passage. The most important 

job of rural Alaska. electrie utilities is to provide reliable electric service to communities during 

the extreme winter months . This service is not a convenience as it is in many other parts of the 

country, but a critical life and safety concern of every resident in these communities. The rural 

utilities represented;byAPA~siriiplydo not have thd~financial ability to absorb the increased 

operating costs required to comply with the new numerical emission standards for CO, including 

retrofitting stacks for the oxidation catalyst after-treatment control arid the frequent source 

testing. 

APA appreciates the consideration that EPA provided to certain rural Alaska communities by 

exempting communities not accessible by the FAHS from meeting the CO emission standards. 

By defining Generally Available Control Technology (GACT) for these communities as 

management practices for non-emergency CI RICE less than or equal to .3oo horsepower, the 

EPA appropriately addressed air quality standards while also, considering the unique 

circumstances of rural Alaska. EPA recognized that CI area source engines located in remote 

areas of Alaska have special challenges that should be taken into consideration. 
Unfortunately, the definition of rural Alaska as listed in the ruling excludes many rural coastal 

communities served by the Alaska Marine Highway with drive-on ferry service, which is 

considered part of the FAHS. Many of these coastal communities have either developed 

hydroelectric power plants or are currently in the development stages of hydroelectric plants 

and other alternatives to diesel generation. Ironically, the increased cost of meeting air quality 

standards competes and even detracts from these projects, which provide the ultimate solution 

to improving air quality standards. 

Also excluded from this narrow definition of rural Alaska are the rural standalone electric 

generating utilities that operate isolated grids not connected to Alaska's integrated "Railbelt" 

electric system, despite their access to a land-based road system. These rural communities have 

the same financial constraints and reliance on redundant diesel-generating capacity as the rural 

communities inaccessible to the FAHS. 

The more urban areas of Alaska are interconnected by electrical transmission lines and a roadbased highway system ; however, most of these "Railbelt" communities do not rely on dieselpowered electric generation . Most "Railbelt" utilities, with the exception of the northern 

Fairbanks region, are powered by natural gas. Dependence on diesel-powered electric 

generation is what distinguishes urban and rural Alaska, not the FAHS. The current definition 

of rural Alaska, as stated in the final rule, does not offer relief to the numerous communities that 

are also challenged by difficult transportation logistics, severe winter weather, short 

construction seasons, isolated grid systems, and unique reliance on redundant diesel-generated 

capacity. 

APA respectfully requests that EPA extend the definition of rural Alaska's GACT for National 

Emission Standards for Hazardous Air Pollutants (NESHAP) CI RICE in area sources to all 

Alaska area source electric generating utilities, regardless of their accessibility to the FAHS. 

Alaska utilities are willing to comply with the management practices for non-emergency CI 

RICE less than or equal to 30o horsepower. However, it is uncertain if all Alaska utilities can 

finance the high cost of complying with the numerical CO emission standards. 

Thank you for considering the unique circumstances of our state's rural electric utility sector . 

Sincerely, 

Marilyn Leland 

Executive Director 

cc: EPA Region io, Office of Air, Waste, and Toxics (AWT-107) 

Senator Lisa Murkowski, US Senate 

Senator Mark Begich, US Senate 

Representative Don Young, US House of Representatives 
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