~ CassRural Water Users District V BOX 98 • 131 MAPLE STREET

KINDRED, NORTH DAKOTA 58051

PHONE: 701-428-3139 • FAX: 701-428-3130

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 annually 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

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 contemplated

Equal Opportunity Employer

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The Honorable Lisa Jackson

November 5,2010

Page 2

in the rule, I believe it should not make any difference under what conditions that unit is

operated within the 100 hours of allowable non-emergency operation.

In conclusion, Cass Rural Water District 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.

Thank you for your prompt attention and I look forward to your response.

Jerry lomeke

General Manager

Cass Rural Water District

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cc: Robert Wayland, EPA

Melanie King, EPA

Kevin Bromberg, SBA