November 8, 2010 

The Honorable Lisa Jackson 201 , f°~'OY 16 PM 3 : 45 

Administrator 

United States Environmental Protection Agenc~ -

Ariel Rios Building (Mail Code 1101) ~ ~~~I ~' 

1200 Pennsylvania Ave, NW 

Washington, D.C . 20460 

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FARGO~J " MOORH EAD 

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, 

201, (75 Fed. Reg. 51,570). 

The Fargo-Moorhead Convention & Visitors Bureau 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 in 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 . 

The Fargo-Moorhead Convention & Visitors Bureau 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 non-emergency use of a stationary engine generator 

poses little health risk or environmental 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 100 hours of 

allowable non-emergency operation . 

In conclusion, the Fargo-Moorhead Convention & Visitors Bureau 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. 

Fargo-Moorhead 

Convention & Visitors Bureau 

2001 44th St . S. 

Fargo . ND 58103 

800-235-7654 

701-282-3653 

701-282-4366 (fax) 

info@fargomoorhead .org 

www.fargomoorhead.org 
The Honorable Lisa Jackson 

November 8, 2010 

Page 2 

The Fargo-Moorhead Convention and Visitors Bureau respectfully requests consideration of its 

request and proposed changes, and thanks the EPA in advance for the same. Thank you for your 

prompt attention, and I look forward to your response. 

Cole Carley, President and CEO 

cc: Robert Wayland, EPA 

Melanie King, EPA 

Kevin Bromberg, EPA 
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