November 8, 2010

The Honorable Lisa Jackson 

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Re: Petition for Reconsideration of Portions of the Final Rule: National Emission Standardsfor Hazardous Air Pollutants for Reciprocating Internal Combustion Engines Dear AdministratorJackson: I amwriting in support ofthe 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 programby 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 ofoperation logged on the generator for this programhas not exceeded 100 hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100hours annually for non-emergency situations, why should it make any difference how

a business chooses to operate its generatorwithin that 100hour limitation? In other words, why are there restrictions within those 100 hours of non-emergency use for peak shaving? The option to use mygenerator as part of a peak shaving programon a limited basis in important to me and helps my cooperative operate its distribution systemmost 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 ofemergency stationary engine generators as they pertain to use for peak shaving. Since the EPA has determined that 100 hours of non-emergency use ofa stationary engine generator poses little health risk or environmental harmabove that already contemplated in the rule, I believe it should not make any difference underwhat conditions the unit is operated within that 100hours 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. Assumingthe 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.orgThe 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.Y. C

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