October 29, 2010

The Honorable L isa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania 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, 2020, Peti tion 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)

. Northwest Iowa Power Cooperative (NIPCO) is a Generation and Transmission Cooperative headquartered in Le Mars, I owa. NIPCO provides power and various services to its 7 member cooperatives and municipals in western Iowa that covers 6,500 square miles. NIPCO and its Member Sy stems have also had a ve ry successful active load management sy stem in place since 1983. Over 50% of the 31,000 consumer

- owners participate in this demand

- side management program. If left in place, the EPA National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE NESHAP) rule will severel y restrict and limit our ability

to maximize efficient operations of our electric s ys tems. This ruling will also have negative power supply

implications as we will be unable to operate our s y stem as efficiently as we current do. This will increase our costs and ultimately our rates to the consumer

- owners. Along with other parts of our country , w estern Iowa struggles to meet the challenges of the downturn in the country ’s econom y . Unemplo ym ent is high, people are struggling to make en d s meet and businesses are fighting to stay open . T his is certainly not the time to place additional burdens on them. Distribution cooperatives, having no major electric generation facilities of their own, are concerned primaril y with distributing electric power to their retail consumers. They simply do not have the resources or a practical reason to keep track of and review the many EPA rulemaking activities under the Clean Air Act to see if one of t hese rulemakings may

have an impact on their operation of delivering electrical power. Without an outreach from EPA, which was absent in these rulemakings, these small entities could not anticipate that the proposed rule for emergency

generators would und ermine and destroy their very

practical and highl y successful peak shaving programs.The bulk of the small emergency generating units, the subject matter of this petition, are owned by the rural consumer

- owners of the electric cooperatives and not by the i ndividual electric cooperatives. These small emergency generating units are utilized in an efficient and productive manner for the benefit of their rural consumer

- owners. It is hard to understand and explain that the efficiency benefits derived from the use of these resources would be wiped out by a Federal Government that professes goals of increased energy efficiency

and resource conservation. NRECA’s p etition addresses restrictions contained in the final rule that prohibit the use of small emergency generating units for peak shaving programs and limits demand reduction service beginning in 2013 without the addition of expensive emission reduction technology on units larger than a specified size

. To help operate our electric sy stem more efficiently and maximize our power supply , our load management s ys tem includes a peak shaving program that uses the engines you will be regulating and restricting the use of. Without the use of these back

- up generators, the cost of power will increase as there will be no other cost

- effective option to reduce our demand during peak usage times . The added capital expenditures placed on our consumer

- owner to make the required upgrades under this regulatory mandate places a very

significant financial burden on them. This may force us to cease future peak shaving demand side management program as they will no longer be cost effective for us or the consumer

- owner to consider

. We support the recommendation contai ned in NRECA’s petition regarding removal of the restrictions on the use of these engines for peak shaving and demand reduction purposes in the 100 hours of non

- emergency operations allowed in the rule. The u se of these engines up to 100 hours for non

- eme rgency operation per ye ar, as already allowed in the final rule, would not cause any additional emissions and therefore, no additional health risk or environmental harm above that already contemplated in the rule. In conclusion, NIPCO, its Member Cooper atives support protecting public health and the environment. However, in this case the restrictions are unnecessary , too severe, will cause a significant detriment to our consumer

- owners, and will not result in any meaningful environmental benefit. We urge the agency to reconsider these restrictions on peak shaving and demand reduction contained in the final rules and amend the rules avoid diminish ing the value of th ese p rograms and increase the cost of power to our consumer
- owners. If you have any questions or need additional information, please contact me at 712

- 546

- 4141. Thank yo u Administrator Jackson for your consideration of our request . On behalf of our 31,000 consumer - owners, we e xpress our desire you will respond favorabl y on this critically important issue. Sincerel y, Kent D. Pauling Executive Vice President and General Manager

cc: Robert Wayland Melanie King Kevin Bromberg, SBA