November 10, 2010 

The Honorable Lisa 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, 2010, Petition for Reconsideration to 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). 

Pierce Pepin Cooperative Services (PPCS), headquartered in Ellsworth, Wisconsin, is one of the 

25 member cooperatives of Dairyland Power Cooperative (DPC). Dairyland Power Cooperative, 

headquartered in La Crosse, Wisconsin, is a generation and transmission cooperative. PPCS is 

an electric cooperative serving over 6,500 electric members throughout most of Pierce County 

and portions of Pepin, St. Croix and Buffalo counties in west central Wisconsin. 

PPCS, in conjunction with DPC, has had a very successful active load management system in 

place for nearly 30 years. Over 60 percent of PPCS members participate in this demand-side 

management program. 

Specifically, I am very concerned about the impact to our rural members who own and operate 

their own generators. These members are small business owners and dairy farmers. The EPA 

National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal 

Combustion Engines (NESHAP RICE) rule will severely limit our ability to maximize efficient 

operations of our electric system and negatively impact our power supply. This will increase our 

costs and, ultimately, raise rates to our members. 

PPCS has no major electric generation facilities of our own. Our primary concern is with 

distributing electric power to our retail consumers/member-owners. PPCS does not have the 

resources to keep track of and review the many EPA rulemaking activities under the Clean Air 
The Honorable Lisa Jackson 

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November 10, 2010 

Act to verify if any of these regulations may impact our business of delivering electrical power. 

Without an outreach from EPA, which was absent in these rulemakings, PPCS could not 

anticipate that the proposed rule for emergency generators would undermine and destroy our 

very practical and highly successful peak-shaving programs. 

We currently have dairy farmers evaluating emergency generators for business continuity 

reasons and for peak shaving to help lower their operating costs. We have informed these dairy 

producers of the EPA’s plans and the current 2013 deadline. These producers are appalled that 

the dairy farmer and agriculture, both great stewards of the environment who offer huge potential 

for supporting renewable energy resources, are the very ones to be hurt the most from this 

rulemaking. 

 

The majority of small emergency generating units, the subject matter of this petition, are owned 

by rural members of the electric cooperatives. These units are utilized in an efficient and 

productive manner for the benefit of our rural members. It is hard to understand and explain why 

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 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. 

To help operate our electric distribution system more efficiently and maximize our power supply, 

our load management system includes a peak-shaving program that uses the engines you will be 

regulating and restricting the use of. Without the use of these backup generators, power costs 

will increase with no other cost-effective option to reduce our demand during peak usage times. 

The added capital expenditures required by our members to make the necessary upgrades under 

this regulatory mandate place a very significant financial burden on them. This may force us to 

cease future peak-shaving demand-side management programs that will no longer be cost 

effective for us or the member to consider. 

We support NRECA’s petition to remove restrictions on the use of these engines for peak 

shaving and demand reduction purposes in the 100 hours of nonemergency operations allowed in 

the rule. The use of these engines for nonemergency operation up to 100 hours per year, as 

already allowed in the final rule, would not cause any additional emissions and, therefore, no 

additional health risk or environmental harm above what is already contemplated in the rule. 

PPCS supports protecting public health and the environment. However, in this case, the 

restrictions are unnecessary, too severe, will cause a significant detriment to our 

consumers/member-owners, and will not result in any meaningful environmental benefit. We 

urge the agency to reconsider these restrictions on peak shaving and demand reduction as 
The Honorable Lisa Jackson 

Page 3 

November 10, 2010 

contained in the final rules, and to amend the rules to avoid diminishing the value of these 

programs that would increase the cost of power to our consumers/member-owners. 

Thank you, Administrator Jackson, for your consideration of our request. On behalf of our 

consumers/member-owners, we urge you to respond favorably on this critical issue. PPCS also 

believes it is necessary and urges EPA to amend the March 2010 CI NESHAP RICE final rule 

and the July 2006 NSPS rule with conforming changes so all applicable rules are clear and 

consistent. 

If you have any questions or need additional information, please contact me at 715-273-4355. 

Sincerely, 

PIERCE PEPIN COOPERATIVE SERVICES 

Larry J Dokkestul 

President & CEO 

LJD:lal 

cc: Robert Wayland 

 Melanie King 

 Kevin Bromberg, SBA