DAKOTA VALLEY 

C ELECTRIC COOPERATIVE 

Your Touchstone Energy* Partner 0 

November 5, ?010 

The Honorable Lisa Jackson 

Administrator 

United States Environmental Protection Agency 

Ariel Rios Building (Mail Code 1101) 

1200 Pennsylvania Ave . . NW 

Washington, D.C . 20460 

~1R~' N HERN 

Elect»c Cooperative PLAINS - 

a% 

0 

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: 

l am writing in support of the National Rural Electric Cooperative Association's (NRECA) 

October 19, 2020, Petition for Reconsideration of portions of the Final National Emission 

Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 

promulgated on August 20, 2010, ('5 Fed. Reg. S1,S770). 

Dakota Valley Electric Cooperative and Northern Plains Electric Cooperative are electric 

cooperatives providing central station electric service to rural consumers in southeast and east 

central North Dakota. Dakota Valley has a service area covering 5,700 square miles in portions 

of eight counties in SE ND. Dakota Valley serves approximately 6,000 consumers over 4,800 

miles of distribution line - a density of 1 .25 consumers per mile of line. Northern Plains' service 

area covers 9,000 square miles in portions of 11 counties. Northern Plains 11,700 member 

consumers are served over 6,900 miles of line, with a customer base largely agricultural but also 

including portions of two Native American reservations . 

As distribution cooperatives primarily concerned with distributing power to end consumers, 

Dakota Valley and Northern Plains do not own or maintain generation facilities but rather rely on 

their G&T cooperatives for po%zer supply . Additionally, Dakota Valley and Northern Plains do 

not provide small generator services for their members . Any generators utilized by cooperative 

customers are owned and maintained by those constuners . Without any direct involvement in 

generator utilization, Dakota Valley and Northern Plains did not seek out information on pending 

changes in generator regulations, and were unaware of the implications of proposed rulemaking 

for emergency generators. 

NRECA's petition 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. 

Dakota Y'alle~~ Electric Cooperative, 'Z96 Kxy~ 281. Edgeley, ND 38-133-9503 

Northern Plains Electric Cooperative, 1513 «' Afain, PO Box 180, Carrington, A'"D 584?1-0180 
The Honorable Lisa Jackson 

November 5, 2010 

Page 2 

Both Dakota Valley and Northern Plains control system demand on an on-going basis, 

attempting to lower the monthly demand peak and improve the load factor of the power we 

purchase . Included with the devices controlled by the cooperative are consumer-owned diesel 

generators which range in size from 25 kW up to 500 kW. Together these generators under 

control total approximately 1,500 kW of load. The generators are interconnected to the 

cooperatives' load management system and are available to be turned on and off periodically 

during the course of each month to lower the cooperatives' system demand peaks . 

For our consumers, the main reason for having diesel generators is to provide emergency power 

in the event of loss of central station service. The cooperatives are able to take advantage of the 

generator opportunity to increase the efficiency of their electrical system operation. passing on 

the savings to those consumers with controlled generators. The cooperatives are further able to 

utilize consumer generation during times of electrical grid disruption that causes regional 

overload. By initiating control during those occurrences, the cooperatives are able to drop load 

and assist in stabilizing the transmission system . 

We anticipate that the implementation of EPA's final RICE NESHAP rules will cause many of 

our consumers with controlled generators to pull out of the cooperatives' control programs, thus 

reducing the efficiency of the cooperatives' power supply and eroding the reliability of the 

transmission grid. 

Ale respectfully encourage EPA to remove the restrictions on peak shaving and demand 

reduction service for diesel generators, along with the 50-hour limitation on non-emergency 

service . This step would provide for 100 hours per year for non-emergency service, allowing for 

vastly improved utilization at a small cost in terms of increased operation. 

We thank you for your consideration of this request. Please give me a call at 1-800-342-4671 in 

the event of questions or the need for further information . 

Sincerely, 

DAKOTA VALLEY ELECTRIC COOPERATIVE 

THERN PLAINS ELECTRIC COOPERATIVE 

~- 

Jav aFos~on 

er~L°_~lanager 
39Vlsod sn 

= -? Q = 

, 

w 

d 

x 

., ~ . 

- 

TI x 

_ .) I , 63~ 

r 

ca i :~ e 

T 

° ~J`~ 3 

Z 

~x 

4 

!V 

r 

ao 

, ; , 

! 

K . 

el I.-