Alaska Power Association 703West 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 CFRPart 63, Subpart ZZZZ; Docket #OAR-2oo2-0059 Dear AdministratorJackson: ru C= rn C .a 0 N co

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 newnumerical 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 significantfinancial 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 FederalAid Highway System(FAHS) . Alaska PowerAssociation is the statewide trade association for the electric utilities that supply power to.communities fromBarrow toAdak and down the Inside Passage. The most important jobof ruralAlaska.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 otherparts ofthe country, but a critical life and safetyconcern ofevery resident in these communities. The rural utilities represented;byAPA~siriiplydo not have thd~financial abilityto absorb the increased operating costs requiredto comply with the new numerical emission standards for CO, including retrofitting stacks for the oxidation catalyst after-treatment control arid thefrequent source testing. APAappreciates the consideration that EPA provided to certain rural Alaska communities by exempting communities not accessible by the FAHS frommeeting the COemission 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 ofAlaska 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 fromthese projects, which provide the ultimate solution to improvingair quality standards. Also excluded from this narrowdefinition 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 ruralAlaska, as stated in thefinal 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 EPAextend 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 ofcomplyingwith the numerical COemission standards. Thankyoufor considering the unique circumstances ofour state's rural electric utilitysector. 

### Sincerely, Marilyn Leland Executive Director cc: EPARegion io, Office ofAir, Waste, andToxics (AWT-107) Senator Lisa Murkowski, US Senate Senator Mark Begich, US Senate Representative DonYoung, US House of Representatives.

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