# DAKOTAVALLEY

C ELECTRIC COOPERATIVE Your Touchstone Energy* Partner 0 November 5, ?010 The Honorable LisaJackson Administrator 

### United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200Pennsylvania Ave.. NW Washington, D.C. 20460 

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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 amwriting in support of the National Rural Electric Cooperative Association's (NRECA) October 19, 2020, Petition for Reconsideration of portions ofthe 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 5,700square miles inportions ofeight counties in SE ND . Dakota Valley serves approximately 6,000 consumers over 4,800 miles ofdistribution 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 11,700member consumers are served over 6,900 miles ofline, with a customer base largely agricultural but also including portions oftwo 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 ofthe implications ofproposed rulemaking for emergency generators. NRECA's petition addresses restrictions contained in the final rule that prohibit the use ofsmall emergency generating units for peak shaving programs and limits demand reduction service beginning in 2013 without the addition ofexpensive 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 systemdemand on an on-going basis, attempting to lower the monthly demand peak and improve the load factor ofthe power we purchase. Included with the devices controlled by the cooperative are consumer-owned diesel generators which range in size from25 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 systemand are available to be turned on and off periodically during the course ofeach monthto lower the cooperatives' systemdemand peaks. For our consumers, the main reason for having diesel generators is to provide emergency power in the event ofloss of central station service. The cooperatives are able to take advantage ofthe generator opportunity to increase the efficiency oftheir electrical systemoperation. passing on the savings to those consumers with controlled generators. The cooperatives are further able to utilize consumer generation during times ofelectrical grid disruption that causes regional overload. By initiating control during those occurrences, the cooperatives are able todrop load and assist in stabilizing the transmission system . We anticipate that the implementation of EPA's final RICE NESHAPrules will cause many of our consumers with controlled generators to pull out ofthe cooperatives' control programs, thus reducing the efficiency ofthe cooperatives' power supply and eroding the reliability ofthe transmission grid. Ale respectfully encourage EPAto 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 ofquestions or the need for further information. Sincerely, 

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