# ~ Cass Rural Water Users District



# V BO X 9 8 • 131 MAPLE STREET KINDRED , NORTH DAKOTA 58 051 PHONE : 701-4 28 - 3 1 3 9 • FAX : 701 - 4 2 8- 3 1 3 0

November 5, 2010 The Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) l200Pennsylvania 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 19,2010, Petition of 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). Cass Rural Water District is a member

- owner ofCass 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 annual ly 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, 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 bases is important to me and helps my water utility 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. Cass Rural Water District 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 EP A has determined that 100 hours of non - emergency use of a stationary engine generator poses little health risk or environmental harm above that already contemplated

Equa l Oppo rtunity Employer ~a1i!y ~OnTap!The Honorable Lis a Jackson

November 5 , 2010 Page 2 in the rule , I beli eve it s hould not m ake any di ffere nc e under wh at condition s th at unit i s operated within th e 100 hour s of allo w ab le non- e merg enc y op eration
. In conclu s ion , Cass Rural Water Di s trict res p e ctf ully requ es ts th e EP A re con s iders it s propo s ed rule for spark ig nition (SI ) en gi n es. Ass uming the agency reco g ni zes the common-sense lo g ic pre sented in this letter w ith re g ard to the propo s ed SI rules , and th e proposed changes put forth b y NRECA , w e al s o urge the ag ency to apply that same logic to the current RICE rule s so as to make the f inal NESHAP rule con s iste nt and uniform throughout all stationary engine generators powered by liquid fossil-fu e ls
. Th ank you for your prompt attention and I look forward to your respon s e .

Jerry lomeke General Man ager Cass Rural W ater Di strict JB lblj
cc : Rob ert Way l and , EPA M e l ani e Kin g , EP A Kevi n Bromberg , SBA