# Northern Cass school District No. 97 : Home oftheJaguars

. ." ; 16021 10' St. SE Hunter, ND 580

;t8 Phone: (701) 87-1-2322 Fay : (701) 87-1-2422 Dr. Allen But-gad, Superintendent Aaron Schramm, High School Principal C :rysta Wagner, Elementary Principal Julie KFOler, BZdsft9ss ;1'1CrJ1cr.t~c'1- WebSite: tii}ww

.northerncass.kl2.nd.us The Honorable Lisa Jackson Administrator r_1_T__ Novqmber 4, :B0 ~' . <_: ~ United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania Ave., NW Washington, D

.C. 20460 W Re: Petition for Reconsideration of Portions ofthe Final Rule: National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines Dear Administrator Jackson: I amwriting in support ofthe National Rural Electric Cooperative Association's (NRECA) October 19, 2010, Petition for Reconsideration ofportions 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) . Northern Cass is a member-owner ofCass County Electric Cooperative Inc. (CCEC) and is currently participating in its electric load management programby using our stationary engine generator. Theengine 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 programhas not exceeded 100 hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan 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 ofa peak shaving programon a limited basis is important to me and helps my cooperative operate its distribution systemmost effectively. It seems to me that this small change to your rules would make the rules more reasonable without sacrificing air quality. Northern Cass supports NRECA's petition to remove the restrictions in use ofemergency stationary engine generators as they pertain to use for peak shaving. Since the EPA has determined that 100 hours of nonemergency use of a stationary engine generator poses little health risk or envirorunental harmabove that already contemplated in the rule, I believe it should not make any difference under what conditions the unit is operated within that the 100 hours ofallowable non-emergency operation In conclusion, Northern Cass respectfully requests the EPAreconsiders 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 uniformthroughout all stationary engine generators powered by liquid fossil-fuels. Northern Cass respectfully requests consideration of its request and proposed changes, and thanks the EPAin advance for the same. Thank you r your prompt attention and I look forward to your response. Sincerely, 41,0fil Allen Burgad, Supt. - Northern Cass School Districtw : . . M

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