16313 North Dale Mabry Highway P.O. Box 272000 Tampa, Florida 33688

- 2000

Telephone 813.963.0994 Fax 813.264.7906 www.seminole

- electric.com November 8, 2010

The Honorable Lisa Jackson

Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania Ave nue , NW Washington, DC 20460

Re: Comments by Seminole Electric Cooperative, Inc. in Support of NRECA ’ s Petition for

Reconsideration of Portions of the Final Rule: National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines

Docket EPA

- HQ

- OAR

- 2208

- 0708

Dear Administrator Jackson:

Seminole Electri c Cooperative, Inc. (Seminole) is a non

- profit generation and transmission cooperative serving ten non

- profit member distribution cooperatives in Florida. Seminole ’ s
M ember cooperatives serve approximately 1. 6 million electric consumers in 46 of Florida ’ s 67

counties. Most of these consumers live in the rural areas of Florida.

The purpose of this letter is to express our support for the referenced and attached petition by NRECA (a cooperative trade association) seeking reconsideration of certain restrict ions on the operation of emergency engines. Specifically, NRECA is seeking relief from unnecessary limitations imposed on the use of emergency generators for peak shaving and demand reduction. Seminole agrees with NRECA that any such restriction on emerg ency generators is ill advised and unnecessary and requests that EPA remove these restrictions.

NRECA appropriately pointed out that EPA ’ s final rule allows emergency engines to operate for 100 hours per year for non

- emergency purposes, including testin g, maintenance, and emergency demand management. Accordingly, because the rule already contemplates the emission impact from this limited usage, prohibiting the use of such emergency engines for peak shaving or

demand reduction serves no additional enviro nmental purpose. But this prohibition will have a substantial economic and reliability impact on the cooperatives and consumers they serve. Specifically, prohibiting engines that are used for peak shaving or demand reduction from being

classified as “ eme rgency ” engines would require them to install costly emission controls, even though they would be used for less than 100 hours per year. In many cases, this added cost is prohibitive and these engines would, therefore, not be retained for this purpose wit h the net result being increased cost to consumers. This additional burden is inappropriate and unnecessary, especially in these strained economic times. Moreover, while the NRECA Petition is focused on

EPA ’ s rule regarding spark ignition engines, the sa me problem exists (and should be remedied) for compression ignition engines.Administrator Jackson

November 8, 2010 Page Two

16313 North Dale Mabry Highway P.O. Box 272000 Tampa, Florida 33688

- 2000 Telephone 813.963.0994 Fax 813.264.7906 www.seminole

- electric.com Traumatic weather events such as hurricanes and infrequent but severe cold weather are hazards that impact Florida and are extremely disruptive to regional electric reliability. In many cases, these events can cause thousands of Floridians to take refuge in emergency shelters. This is an especially critical concern in Florida where so many people live in mobile homes. While it may not be economical to install generators just t o handle these types of emergencies, many are justified when they can also be used for non

- emergency events such as peak shaving and demand reduction. Many of these engines provide emergency power to hospitals, emergency shelters,

well fields , water trea tment plants, and retail establishments providing essential services to the public such as fuel, food, and household supplies. Since most of these engines in cooperative

served areas have been provided and cost

- justified by the non

- profit cooperatives due to the shared benefits for emergencies and demand management use, costly retrofits may not be cost

feasible. Allowing the use of these generators for 100 hours of operation will ensure that these emergency engine

- generators are retained as a significant benefit to our member consumers.

In sum, Seminole supports the NRECA Petition and requests that EPA grant reconsideration to remove the unnecessary restrictions on the use of emergency engines. Such revisions would not cause any additional environmental impact beyond that already contemplated in the rule, and would preserve the valuable emergency uses of these engines.

Please contact me if you have any questions or require additional information. I can be reached at (813) 739

- 1233 or mopalinski@semino le

- electric.com.

Sincerely,

Michael P Opalinski Sr. Vice President of Strategic Services

cc: Honorable Bill Nelson

, U.S. Senator (FL) Tim Woodbury

, Seminole CEO Robert Wayland, EPA Melanie King, EPA