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 Avenue, 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 Electric Cooperative, Inc. (Seminole) is a non-profit generation and transmission 

cooperative serving ten non-profit member distribution cooperatives in Florida. Seminole’s 

Member 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 restrictions 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 emergency 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 testing, 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 environmental 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 “emergency” 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 with 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 same 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 to 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 treatment plants, and retail establishments providing essential services to the 

public such as fuel, food, and household supplies. Since most of these engines in cooperativeserved 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 costfeasible. 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@seminole-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