Northern Cass school District No. 97 : 

Home of the Jaguars 

.. " ; 

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- 

Web Site : tii}ww .northerncass.kl2 .nd.us 

The Honorable Lisa Jackson Administrator 

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Novqmber 4, :B 0 

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United States Environmental Protection Agency 

Ariel Rios Building (Mail Code 1101) 

1200 Pennsylvania Ave., N W 

Washington, D.C. 20460 W 

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 for 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) . 

Northern Cass is a member-owner of Cass 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 basis is important to me and helps my cooperative 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 . 

Northern Cass 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 nonemergency use of a stationary engine generator poses little health risk or envirorunental harm above 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 of allowable non-emergency operation 

In conclusion, Northern Cass 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 . 

Northern Cass respectfully requests consideration of its request and proposed changes, and thanks the EPA in 

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 District 
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